# Jeremy Lewi v. Comenity Capital Bank

> District Court, C.D. California · July 14, 2025

URL: https://www.frixlaw.com/law-library/cases/11099710

## Case

- **Court:** District Court, C.D. California
- **Decided:** July 14, 2025
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1
UNITED STATES DISTRICT COURT
2
CENTRAL DISTRICT OF CALIFORNIA
3

4 JEREMY LEWI,
Case No. 2:25-cv-02118-AB-SSC
5
Plaintiff(s),
6 STIPULATED PROTECTIVE
7 v. ORDER1

8 COMENITY CAPITAL BANK,
9
10 Defendants.

11

12
13
1. INTRODUCTION
14
1.1 Purposes and Limitations. Discovery in this action is likely to
15
involve production of confidential, proprietary, or private information for
16
which special protection from public disclosure and from use for any
17
purpose other than prosecuting this litigation may be warranted.
18
Accordingly, the parties hereby stipulate to and petition the court to
19
enter the following Stipulated Protective Order. The parties
20
21 acknowledge that this Order does not confer blanket protections on all
22 disclosures or responses to discovery and that the protection it affords
23 from public disclosure and use extends only to the limited information or
24
25
26
27
1 This Stipulated Protective Order is substantially based on the model
protective order provided under Magistrate Judge Stephanie S.
1 items that are entitled to confidential treatment under the applicable
2 legal principles.
3 1.2 Good Cause Statement.
4 This action is likely to involve trade secrets, consumer information
5 and other valuable research, development, commercial, financial,
6 technical and/or proprietary information for which special protection
7 from public disclosure and from use for any purpose other than
8 prosecution of this action is warranted. Such confidential and
9
proprietary materials and information consist of, among other things,
10
confidential business or financial information, information regarding
11
confidential business practices, or other confidential research,
12
development, or commercial information (including information
13
implicating privacy rights of third parties), information otherwise
14
generally unavailable to the public, or which may be privileged or
15
otherwise protected from disclosure under state or federal statutes, court
16
rules, case decisions, or common law. Accordingly, to expedite the flow of
17
information, to facilitate the prompt resolution of disputes over
18
confidentiality of discovery materials, to adequately protect information
19
the parties are entitled to keep confidential, to ensure that the parties
20
are permitted reasonable necessary uses of such material in preparation
21
22 for and in the conduct of trial, to address their handling at the end of the
23 litigation, and serve the ends of justice, a protective order for such
24 information is justified in this matter. It is the intent of the parties that
25 information will not be designated as confidential for tactical reasons
26 and that nothing be so designated without a good faith belief that it has
27 been maintained in a confidential, non-public manner, and there is good
1 1.3 Acknowledgment of Procedure for Filing Under Seal. The
2 parties further acknowledge, as set forth in Section 12.3, below, that this
3 Stipulated Protective Order does not entitle them to file confidential
4 information under seal; Local Rule 79-5 sets forth the procedures that
5 must be followed and the standards that will be applied when a party
6 seeks permission from the court to file material under seal.
7 There is a strong presumption that the public has a right of access
8
to judicial proceedings and records in civil cases. In connection with
9
non-dispositive motions, good cause must be shown to support a filing
10
under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d
11
1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors
12
Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony
13
Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
14
protective orders require good cause showing), and a specific showing of
15
good cause or compelling reasons with proper evidentiary support and
16
legal justification, must be made with respect to Protected Material that
17
a party seeks to file under seal. The parties’ mere designation of
18
Disclosure or Discovery Material as CONFIDENTIAL does not—
19
without the submission of competent evidence by declaration,
20
establishing that the material sought to be filed under seal qualifies as
21
22 confidential, privileged, or otherwise protectable—constitute good cause.
23 Further, if a party requests sealing related to a dispositive motion
24 or trial, then compelling reasons, not only good cause, for the sealing
25 must be shown, and the relief sought shall be narrowly tailored to serve
26 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,
27 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of
1 seal in connection with a dispositive motion or trial, the party seeking
2 protection must articulate compelling reasons, supported by specific
3 facts and legal justification, for the requested sealing order. Again,
4 competent evidence supporting the application to file documents under
5 seal must be provided by declaration.
6 Any document that is not confidential, privileged, or otherwise
7 protectable in its entirety will not be filed under seal if the confidential
8
portions can be redacted. If documents can be redacted, then a redacted
9
version for public viewing, omitting only the confidential, privileged, or
10
otherwise protectable portions of the document, shall be filed. Any
11
application that seeks to file documents under seal in their entirety
12
should include an explanation of why redaction is not feasible.
13

14
2. DEFINITIONS
15
2.1 Action: The above-captioned matter styled as Jeremy Lewi v.
16
Comenity Capital Bank, U.S District Court for the Central District of
17
18 California, Case No. 2:25-cv-02118-AB-SSC.
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
9
a matter pertinent to the litigation who has been retained by a Party or
10
its 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
19
Record 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
24 of 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
26 are affiliated with a law firm which has appeared on behalf of that party,
27 and 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
21 testimony, conversations, or presentations by Parties or their Counsel
22 that might 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
18 Even after Final Disposition of this litigation, the confidentiality
19 obligations imposed by this Stipulated Protective Order shall remain in
20 effect until a Designating Party agrees otherwise in writing or a court
21 order otherwise directs.
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
25
items 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
16
of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
17
18 or 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
27
material. If only a portion or portions of the material on a page
1 qualifies for protection, the Producing Party also must clearly identify
2 the protected portion(s) (e.g., by making appropriate markings in the
3 margins).
4 A Party or Non-Party that makes original documents available for
5 inspection need not designate them for protection until after the
6 inspecting Party has indicated which documents it would like copied
7 and produced. During the inspection and before the designation, all of
8
the material made available for inspection shall be deemed
9
CONFIDENTIAL. After the inspecting Party has identified the
10
documents it wants copied and produced, the Producing Party must
11
determine which documents, or portions thereof, qualify for protection
12
under this Stipulated Protective Order. Then, before producing the
13
specified documents, the Producing Party must affix the
14
“CONFIDENTIAL” legend to each page that contains Protected
15
Material. If only a portion or portions of the material on a page
16
qualifies for protection, the Producing Party also must clearly identify
17
the protected portion(s) (e.g., by making appropriate markings in the
18
margins).
19
(b) for testimony given in depositions that the Designating Party
20
identify the Disclosure or Discovery Material on the record, before the
21
22 close of the deposition all protected testimony.
23 (c) for information produced in some form other than
24 documentary and for any other tangible items, that the Producing Party
25 affix in a prominent place on the exterior of the container or containers
26 in which the information is stored the “CONFIDENTIAL” legend. If only
27 a portion or portions of the information warrants protection, the
1 portion(s).
2 5.3 Inadvertent Failures to Designate. If timely corrected, an
3 inadvertent failure to designate qualified information or items does not,
4 standing alone, waive the Designating Party’s right to secure protection
5
under this Order for such material. Upon timely correction of a
6
designation, the Receiving Party must make reasonable efforts to assure
7
that the material is treated in accordance with the provisions of this
8
Stipulated Protective Order.
9

10
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
11
6.1 Timing of Challenges. Any Party or Non-Party may
12
challenge a designation of confidentiality at any time that is consistent
13
14 with the court’s Scheduling Order.
15 6.2 Meet and Confer. The Challenging Party shall initiate the
16 dispute resolution process under Local Rule 37.1 et seq. and with
17 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-
18 Discovery Motion Conference.”2
19 6.3 The burden of persuasion in any such challenge proceeding
20 shall be on the Designating Party. Frivolous challenges, and those
21 made for an improper purpose (e.g., to harass or impose unnecessary
22 expenses and burdens on other parties) may expose the Challenging
23
Party to sanctions. Unless the Designating Party has waived or
24
withdrawn the confidentiality designation, all parties shall continue to
25
afford the material in question the level of protection to which it is
26

27
2 Judge Christensen’s Procedures are available at
1 entitled under the Producing Party’s designation until the court rules on
2 the challenge.
3
4 7. ACCESS TO AND USE OF PROTECTED MATERIAL
5
7.1 Basic Principles. A Receiving Party may use Protected
6
Material that is disclosed or produced by another Party or by a Non-
7
Party in connection with this Action only for prosecuting, defending, or
8
attempting to settle this Action. Such Protected Material may be
9
disclosed only to the categories of persons and under the conditions
10
described in this Order. When the Action reaches a Final Disposition, a
11
Receiving Party must comply with the provisions of section 13 below.
12
Protected Material must be stored and maintained by a Receiving
13
Party at a location and in a secure manner that ensures that access is
14
limited to the persons authorized under this Stipulated Protective
15
Order.
16
17 7.2 Disclosure of “CONFIDENTIAL” Information or Items.
18 Unless otherwise ordered by the court or permitted in writing by the
19 Designating Party, a Receiving Party may disclose any information or
20 item designated “CONFIDENTIAL” only:
21 (a) to the Receiving Party’s Outside Counsel of Record in this
22 Action, as well as employees of said Outside Counsel of Record to whom
23 it is reasonably necessary to disclose the information for this Action;
24 (b) to the officers, directors, and employees (including House
25 Counsel) of the Receiving Party to whom disclosure is reasonably
26
necessary for this Action;
27
(c) to Experts (as defined in this Order) of the Receiving Party to
1 whom disclosure is reasonably necessary for this Action and who have
2 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
3 (d) to the court and its personnel;
4 (e) to court reporters and their staff;
5 (f) to professional jury or trial consultants, mock jurors, and
6 Professional Vendors to whom disclosure is reasonably necessary for
7 this Action and who have signed the “Acknowledgment and Agreement
8
to Be Bound” (Exhibit A);
9
(g) to the author or recipient of a document containing the
10
information or a custodian or other person who otherwise possessed or
11
knew the information;
12
(h) during their depositions, to witnesses, and attorneys for
13
witnesses, in the Action to whom disclosure is reasonably necessary,
14
provided: (1) the deposing party requests that the witness sign the
15
“Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
16
witness will not be permitted to keep any confidential information
17
unless they sign the “Acknowledgment and Agreement to Be Bound”
18
(Exhibit A), unless otherwise agreed by the Designating Party or
19
ordered by the court. Pages of transcribed deposition testimony or
20
exhibits to depositions that reveal Protected Material may be separately
21
22 bound by the court reporter and may not be disclosed to anyone except
23 as permitted under this Stipulated Protective Order; and
24 (i) to any mediator or settlement officer, and their supporting
25 personnel, mutually agreed upon by any of the parties engaged in
26 settlement discussions.
27
1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
2 PRODUCED IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in
4
other litigation that compels disclosure of any information or items
5
designated in this Action as “CONFIDENTIAL,” that Party must:
6
(a) promptly notify in writing the Designating Party. Such
7
notification shall include a copy of the subpoena or court order;
8
(b) promptly notify in writing the party who caused the
9
subpoena or order to issue in the other litigation that some or all of the
10
material covered by the subpoena or order is subject to this Protective
11
Order. Such notification shall include a copy of this Stipulated
12
Protective Order; and
13
14 (c) cooperate with respect to all reasonable procedures sought to
15 be pursued by the Designating Party whose Protected Material may be
16 affected.
17 If the Designating Party timely seeks a protective order, the
18 Party served with the subpoena or court order shall not produce any
19 information designated in this action as “CONFIDENTIAL” before a
20 determination by the court from which the subpoena or order issued,
21 unless the Party has obtained the Designating Party’s permission. The
22 Designating Party shall bear the burden and expense of seeking
23
protection in that court of its confidential material and nothing in these
24
provisions should be construed as authorizing or encouraging a
25
Receiving Party in this Action to disobey a lawful directive from another
26
court.
27
1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 9.1 Application. The terms of this Stipulated Protective Order
4 are applicable to information produced by a Non-Party in this Action and
5 designated as “CONFIDENTIAL.” Such information produced by Non-
6 Parties in connection with this litigation is protected by the remedies
7 and relief provided by this Order. Nothing in these provisions should be
8 construed as prohibiting a Non-Party from seeking additional
9
protections.
10
9.2 Notification. In the event that a Party is required, by a valid
11
discovery request, to produce a Non-Party’s confidential information in
12
its possession, and the Party is subject to an agreement with the Non-
13
Party not to produce the Non-Party’s confidential information, then the
14
Party shall:
15
(a) promptly notify in writing the Requesting Party and the
16
Non-Party that some or all of the information requested is subject to a
17
confidentiality agreement with a Non-Party;
18
(b) make the information requested available for inspection by
19
the Non-Party, if requested.
20
9.3 Conditions of Production. If the Non-Party fails to seek a
21
22 protective order from this court within 14 days of receiving the notice
23 and accompanying information, the Receiving Party may produce the
24 Non-Party’s confidential information responsive to the discovery request.
25 If the Non-Party timely seeks a protective order, the Receiving Party
26 shall not produce any information in its possession or control that is
27 subject to the confidentiality agreement with the Non-Party before a
1 Non-Party shall bear the burden and expense of seeking protection in
2 this court of its Protected Material.
3
4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
5 MATERIAL
6
If a Receiving Party learns that, by inadvertence or otherwise, it
7
has disclosed Protected Material to any person or in any circumstance
8
not authorized under this Stipulated Protective Order, the Receiving
9
Party must immediately (a) notify in writing the Designating Party of
10
the unauthorized disclosures, (b) use its best efforts to retrieve all
11
unauthorized copies of the Protected Material, (c) inform the person or
12
persons to whom unauthorized disclosures were made of all the terms of
13
this Order, and (d) request such person or persons to execute the
14
“Acknowledgment and Agreement to Be Bound” (Exhibit A).
15

16
17 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
18 OTHERWISE PROTECTED MATERIAL
19
When a Producing Party gives notice to Receiving Parties that
20
certain inadvertently produced material is subject to a claim of privilege
21
or other protection, the obligations of the Receiving Parties are those set
22
forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This
23
provision is not intended to modify whatever procedure may be
24
established in an e-discovery order that provides for production without
25
prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
26
Rules of Evidence, insofar as the parties reach an agreement on the
27
1 attorney-client privilege or work product protection, the parties may
2 incorporate their agreement in the stipulated protective order
3 submitted to the court.
4
5 12. MISCELLANEOUS
6
12.1 Right to Further Relief. Nothing in this Stipulated
7
Protective Order abridges the right of any person to seek its
8
modification by the court in the future.
9
12.2 Right to Assert Other Objections. By stipulating to the entry
10
of this Stipulated Protective Order no Party waives any right it
11
otherwise would have to object to disclosing or producing any
12
information or item on any ground not addressed in this Stipulated
13
Protective Order. Similarly, no Party waives any right to object on any
14
ground to use in evidence of any of the material covered by this
15
Stipulated Protective Order.
16
17
12.3 Filing Protected Material. A Party that seeks to file under
18 seal any Protected Material must comply with Local Rule 79-5.
19 Protected Material may only be filed under seal pursuant to a court
20 order authorizing the sealing of the specific Protected Material at issue.
21 If a Party's request to file Protected Material under seal is denied by the
22 court, then the Receiving Party may file the information in the public
23 record unless otherwise instructed by the court.
24 13. FINAL DISPOSITION
25
After the Final Disposition of this Action, as defined in paragraph
26
4, within 60 days of a written request by the Designating Party, each
27
Receiving Party must return all Protected Material to the Producing
1 Party or destroy such material. As used in this subdivision, “all
2 Protected Material” includes all copies, abstracts, compilations,
3 summaries, and any other format reproducing or capturing any of the
4 Protected Material. Whether the Protected Material is returned or
5 destroyed, the Receiving Party must submit a written certification to
6 the Producing Party (and, if not the same person or entity, to the
7 Designating Party) by the 60 day deadline that (1) identifies (by
8 category, where appropriate) all the Protected Material that was
9
returned or destroyed and (2) affirms that the Receiving Party has not
10
retained any copies, abstracts, compilations, summaries or any other
11
format reproducing or capturing any of the Protected Material.
12
Notwithstanding this provision, Counsel is entitled to retain an archival
13
copy of all pleadings, motion papers, trial, deposition, and hearing
14
transcripts, legal memoranda, correspondence, deposition and trial
15
exhibits, expert reports, attorney work product, and consultant and
16
expert work product, even if such materials contain Protected Material.
17
Any such archival copies that contain or constitute Protected Material
18
remain subject to this Protective Order as set forth in Section 4.
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 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8 || DATED: July 9, 2025 /s/ Michelle F. Catapang
? Tomio B. Narita
10 Nathan A. Searles
Wl Michelle F. Catapang
Attorneys for Defendant
12
13 || DATED: July 9, 2025 /s/ Nicholas J. Enns
14 Matthew M. Loker
15 Nicholas J. Enns
6 Attorneys for Plaintiff
17
18
FOR GOOD CAUSE SHOWN, IT IS SO ORDEBED.
19
20
DATED: July 14, 2025
21
STEPHANIE 8. CHRISTENSEN
22 United States Magistrate Judge
23
24
25
26
27
28

1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2

3
I, ________________________ [print or type full name], of
4
_________________ [print or type full address], declare under
5
penalty of perjury that I have read in its entirety and understand the
6
Stipulated Protective Order that was issued by the United States
7
District Court for the Central District of California on [date] in the
8
case of Jeremy Lewi v. Comenity Capital Bank, U.S District Court for
9
the Central District of California, Case No. 2:25-cv-02118-AB-SSC . I
10
agree to comply with and to be bound by all the terms of this
11
Stipulated Protective Order and I understand and acknowledge that
12
failure to so comply could expose me to sanctions and punishment in
13
14 the nature of contempt. I solemnly promise that I will not disclose in
15 any manner any information or item that is subject to this Stipulated
16 Protective Order to any person or entity except in strict compliance
17 with the provisions of this Order.
18 I further agree to submit to the jurisdiction of the United States
19 District Court for the Central District of California for the purpose of
20 enforcing the terms of this Stipulated Protective Order, even if such
21 enforcement proceedings occur after termination of this action. I
22 hereby appoint ________________________ [print or type full name]
23
of _________ [print or type full address and telephone number] as
24
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

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11099710. Public record. Not legal advice.