# Schatz v. Live Auctioneers, LLC

> District Court, C.D. California · August 27, 2025

URL: https://www.frixlaw.com/law-library/cases/11131086

## Case

- **Court:** District Court, C.D. California
- **Decided:** August 27, 2025
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

| Stephen M. Doniger, Esq. (SBN 179314)
2 || stephen@donigerlawfirm.com
David Shein (SBN 230870)
3 david@donigerlawfirm.com
4 || DONIGER / BURROUGHS
603 Rose Avenue
5 Venice, California 90291
6 || Telephone: (310) 590-1820
7 Attorneys for Plaintiffs
8
9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
1]
12 HOWARD SCHATZ, an individual; Case No. 2:24-cv-09963-MWF-RAO
3 BEVERLY ORNSTEIN, an individual | Hon. Rozella A. Oliver Presiding
14 || Plaintiffs,
15 STIPULATED PROTECTIVE
ORDER!
16 VS.
17
12 LIVE AUCTIONEERS, LLC, a New
York Limited Liability Company, doing
19 business as “JASPER 52;” and DOES I-
20 10, inclusive,
21 Defendants
22
23
24
25
26
27
9g || | This Stipulated Protective Order is substantially based on the model protective
order provided under Magistrate Judge Rozella A. Oliver’s Procedures.

Vly, A. 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 prosecuting this litigation may
> || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
6 || enter the following Stipulated Protective Order. The parties acknowledge that this
7 || Order does not confer blanket protections on all disclosures or responses to
8 discovery and that the protection it affords from public disclosure and use extends
? only to the limited information or items that are entitled to confidential treatment
10 | under the applicable legal principles.
B. GOOD CAUSE STATEMENT
12 This action is likely to involve customer and pricing lists and other valuable
13 research, development, commercial, financial, technical, and/or proprietary
14 | information for which special protection from public disclosure and from use for
I5 any purpose other than prosecution of this action is warranted. Such confidential
16 | and proprietary materials and information consist of, among other things,
|| confidential business or financial information, information regarding confidential
18 |) business practices, or other confidential research, development, or commercial
19 || information (including information implicating privacy rights of third parties),
20 || information otherwise generally unavailable to the public, or which may be
21 privileged or otherwise protected from disclosure under state or federal statutes,
22 || court rules, case decisions, or common law. Accordingly, to expedite the flow of
23 || information, to facilitate the prompt resolution of disputes over confidentiality of
24 discovery materials, to adequately protect information the parties are entitled to keep
confidential, to ensure that the parties are permitted reasonable necessary uses of
26 || such material in preparation for and in the conduct of trial, to address their handling
27 |! at the end of the litigation, and serve the ends of justice, a protective order for such
28

1 || information is justified in this matter. It is the intent of the parties that information
2 || will not be designated as confidential for tactical reasons and that nothing be so
3 designated without a good faith belief that it has been maintained in a confidential,
4 non-public manner, and there is good cause why it should not be part of the public
> || record of this case.
6 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
7 The parties further acknowledge, as set forth in Section 12.3, below, that this
8 Stipulated Protective Order does not entitle them to file confidential information
? || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
10 || and the standards that will be applied when a party seeks permission from the court
11 to file material under seal.
12 There 1s a strong presumption that the public has a right of access to judicial
13 proceedings and records in civil cases. In connection with non-dispositive motions,
14 good cause must be shown to support a filing under seal. See Kamakana v. City and
I5 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
16 | Corp., 307 F.3d 1206, 1210-11 (9th Cir_2002); Makar-Welbon v. Sony Electrics,
17 ll Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
18 require good cause showing), and a specific showing of good cause or compelling
19 reasons with proper evidentiary support and legal justification, must be made with
20 respect to Protected Material that a party seeks to file under seal. The parties’ mere
21 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
22 || without the submission of competent evidence by declaration, establishing that the
23 || material sought to be filed under seal qualifies as confidential, privileged, or
24 ll otherwise protectable—constitute good cause.
25 Further, if a party requests sealing related to a dispositive motion or trial, then
26 compelling reasons, not only good cause, for the sealing must be shown, and the
27 || relief sought shall be narrowly tailored to serve the specific interest to be protected.
28

! ll See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For
2 || each item or type of information, document, or thing sought to be filed or introduced
3 || under seal in connection with a dispositive motion or trial, the party seeking
4 protection must articulate compelling reasons, supported by specific facts and legal
5 justification, for the requested sealing order. Again, competent evidence supporting
6 || the application to file documents under seal must be provided by declaration.
7 Any document that is not confidential, privileged, or otherwise protectable in
8 its entirety will not be filed under seal if the confidential portions can be redacted.
? || If documents can be redacted, then a redacted version for public viewing, omitting
10 only the confidential, privileged, or otherwise protectable portions of the document
11 shall be filed. Any application that seeks to file documents under seal in their
12 entirety should include an explanation of why redaction is not feasible.
132. DEFINITIONS
14 2.1 Action: This pending federal lawsuit Howard Schatz, et al.,v. Live
15 Auctioneers, LLC, et al., Case No.: CV 24-9963-MWF-RAO.
16 2.2 Challenging Party: a Party or Non-Party that challenges the
7 designation of information or items under this Order.
18 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
19 | how it is generated, stored or maintained) or tangible things that qualify for
20 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
21 || the Good Cause Statement.
22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
23 | their support staff).
24 2.5 Designating Party: a Party or Non-Party that designates information or
25 || items that it produces in disclosures or in responses to discovery as
26 || “CONFIDENTIAL.”
27 2.6 Disclosure or Discovery Material: all items or information, regardless
28

1 || of the medium or manner in which it is generated, stored, or maintained (including,
2 among other things, testimony, transcripts, and tangible things) that are produced or
3 generated in disclosures or responses to discovery in this matter.
4 2.7 Expert: a person with specialized knowledge or experience in a matter
5 pertinent to the litigation who has been retained by a Party or its counsel to serve as
6 || an expert witness or as a consultant in this Action.
7 2.8 House Counsel: attorneys who are employees of a party to this Action.
8 || House Counsel does not include Outside Counsel of Record or any other outside
? |! counsel.
10 2.9 Non-Party: any natural person, partnership, corporation, association or
1} other legal entity not named as a Party to this action.
12 2.10 Outside Counsel of Record: attorneys who are not employees of a
13 party to this Action but are retained to represent or advise a party to this Action and
14 || have appeared in this Action on behalf of that party or are affiliated with a law firm
13 |! that has appeared on behalf of that party, and includes support staff.
16 2.11 Party: any party to this Action, including all of its officers, directors,
V7 employees, consultants, retained experts, and Outside Counsel of Record (and their
18 support staffs).
19 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
20 Discovery Material in this Action.
21 2.13 Professional Vendors: persons or entities that provide litigation
22 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
23 || demonstrations, and organizing, storing, or retrieving data in any form or medium)
24 |) and their employees and subcontractors.
25 2.14 Protected Material: any Disclosure or Discovery Material that is
26 || designated as “CONFIDENTIAL.”
27 2.15 Receiving Party: a Party that receives Disclosure or Discovery
28

! || Material from a Producing Party.
* || 3. SCOPE
3 The protections conferred by this Stipulation and Order cover not only
4 || Protected Material (as defined above), but also (1) any information copied or
5 extracted from Protected Material; (2) all copies, excerpts, summaries, or
6 compilations of Protected Material; and (3) any testimony, conversations, or
7 presentations by Parties or their Counsel that might reveal Protected Material.
8 Any use of Protected Material at trial shall be governed by the orders of the
? |) trial judge. This Order does not govern the use of Protected Material at trial.
10 || 4. | DURATION
Once a case proceeds to trial, information that was designated as
12 || CONFIDENTIAL or maintained pursuant to this protective order used or introduced
|| as an exhibit at trial becomes public and will be presumptively available to all
14 || members of the public, including the press, unless compelling reasons supported by
I5 specific factual findings to proceed otherwise are made to the trial judge in advance
16 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
7 showing for sealing documents produced in discovery from “compelling reasons”
18 || standard when merits-related documents are part of court record). Accordingly, the
19 |! terms of this protective order do not extend beyond the commencement of the trial.
20 5. DESIGNATING PROTECTED MATERIAL
21 5.1 Exercise of Restraint and Care in Designating Material for Protection.
22 || Each Party or Non-Party that designates information or items for protection under
23 || this Order must take care to limit any such designation to specific material that
24 qualifies under the appropriate standards. The Designating Party must designate for
25 protection only those parts of material, documents, items or oral or written
26 || communications that qualify so that other portions of the material, documents, items
27 || or communications for which protection is not warranted are not swept unjustifiably
28

! || within the ambit of this Order.
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 purpose (e.g., to unnecessarily encumber the case development process or to impose
5 unnecessary expenses and burdens on other parties) may expose the Designating
6 Party to sanctions.
7 If it comes to a Designating Party’s attention that information or items that it
8 designated for protection do not qualify for protection, that Designating Party must
? promptly notify all other Parties that it is withdrawing the inapplicable designation.
10 5.2 Manner and Timing of Designations. Except as otherwise provided in
11 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
12 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
|| under this Order must be clearly so designated before the material is disclosed or
14 produced.
I5 Designation in conformity with this Order requires:
16 (a) for information in documentary form (e.g., paper or electronic
17 || documents, but excluding transcripts of depositions or other pretrial or trial
18 proceedings), that the Producing Party affix at a minimum, the legend
19 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
20 |) contains protected material. If only a portion of the material on a page qualifies for
21 protection, the Producing Party also must clearly identify the protected portion(s)
22 (e.g., by making appropriate markings in the margins).
23 A Party or Non-Party that makes original documents available for inspection
24 || need not designate them for protection until after the inspecting Party has indicated
|| which documents it would like copied and produced. During the inspection and
26 || before the designation, all of the material made available for inspection shall be
27 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the
28

1 | documents it wants copied and produced, the Producing Party must determine which
2 || documents, or portions thereof, qualify for protection under this Order. Then,
3 || before producing the specified documents, the Producing Party must affix the
4 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
5 portion of the material on a page qualifies for protection, the Producing Party also
© || must clearly identify the protected portion(s) (e.g., by making appropriate markings
7 || in the margins).
8 (b) for testimony given in depositions that the Designating Party identifies
? || the Disclosure or Discovery Material on the record, before the close of the
10 deposition all protected testimony.
(c) for information produced in some form other than documentary and
for any other tangible items, that the Producing Party affix in a prominent place on
13 || the exterior of the container or containers in which the information is stored the
14 legend “CONFIDENTIAL.” If only a portion or portions of the information
13 || warrants protection, the Producing Party, to the extent practicable, shall identify the
16 protected portion(s).
7 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent
18 |! failure to designate qualified information or items does not, standing alone, waive
19 the Designating Party’s right to secure protection under this Order for such material.
20 Upon timely correction of a designation, the Receiving Party must make reasonable
21 | efforts to assure that the material is treated in accordance with the provisions of this
22 || Order.
23 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
24 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
25 designation of confidentiality at any time that is consistent with the Court’s
26 Scheduling Order.
27 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
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1 || resolution process under Local Rule 37.1 et seq.
2 6.3 The burden of persuasion in any such challenge proceeding shall be on
3 || the Designating Party. Frivolous challenges, and those made for an improper
4 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
5 parties) may expose the Challenging Party to sanctions. Unless the Designating
6 Party has waived or withdrawn the confidentiality designation, all parties shall
7 || continue to afford the material in question the level of protection to which it is
8 | entitled under the Producing Party’s designation until the Court rules on the
? challenge.
10 | 7, ACCESS TO AND USE OF PROTECTED MATERIAL
7.1 Basic Principles. A Receiving Party may use Protected Material that is
12 |! disclosed or produced by another Party or by a Non-Party in connection with this
13 Action only for prosecuting, defending or attempting to settle this Action. Such
14 || Protected Material may be disclosed only to the categories of persons and under the
I> |) conditions described in this Order. When the Action has been terminated, a
16 Receiving Party must comply with the provisions of section 13 below (FINAL
17 || DISPOSITION).
18 Protected Material must be stored and maintained by a Receiving Party at a
19 || location and in a secure manner that ensures that access is limited to the persons
20 || authorized under this Order,
21 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
22 || otherwise ordered by the court or permitted in writing by the Designating Party, a
23 Receiving Party may disclose any information or item designated
24 || “CONFIDENTIAL” only to:
25 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
26 || well as employees of said Outside Counsel of Record to whom it is reasonably
27 necessary to disclose the information for this Action;
28

(b) the officers, directors, and employees (including House Counsel) of
2 || the Receiving Party to whom disclosure is reasonably necessary for this Action and
3 || if the Receiving Party is an individual, then to the individual;
4 (c) Experts (as defined in this Order) of the Receiving Party to whom
> || disclosure is reasonably necessary for this Action and who have signed the
6 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
7 (d) the court and its personnel;
8 (e) court reporters and their staff;
? (f) professional jury or trial consultants, mock jurors, and Professional
10 || Vendors to whom disclosure is reasonably necessary for this Action and who have
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
12 (g) the author or recipient of a document containing the information or a
|| custodian or other person who otherwise possessed or knew the information;
14 (h) during their depositions, witnesses, and attorneys for witnesses, in the
13 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party
16 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
17 || will not be permitted to keep any confidential information unless they sign the
18 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
19 agreed by the Designating Party or ordered by the court. Pages of transcribed
20 deposition testimony or exhibits to depositions that reveal Protected Material may
21 Il be separately bound by the court reporter and may not be disclosed to anyone except
22 || as permitted under this Stipulated Protective Order; and
23 (1) any mediator or settlement officer, and their supporting personnel,
24 mutually agreed upon by any of the parties engaged in settlement discussions.
25 || 8, PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
26 IN OTHER LITIGATION
2] If a Party is served with a subpoena or a court order issued in other litigation
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1 that compels disclosure of any information or items designated in this Action as
2 || “CONFIDENTIAL,” that Party must:
3 (a) promptly notify in writing the Designating Party. Such notification
4 || shall include a copy of the subpoena or court order;
5 (b) promptly notify in writing the party who caused the subpoena or order
© || to issue in the other litigation that some or all of the material covered by the
7 subpoena or order is subject to this Protective Order. Such notification shall include
8 a copy of this Stipulated Protective Order; and
? (c) cooperate with respect to all reasonable procedures sought to be
10 pursued by the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with
12 the subpoena or court order shall not produce any information designated in this
| action as “CONFIDENTIAL” before a determination by the court from which the
14 subpoena or order issued, unless the Party has obtained the Designating Party’s
I5 permission. The Designating Party shall bear the burden and expense of seeking
16 protection in that court of its confidential material and nothing in these provisions
17 || should be construed as authorizing or encouraging a Receiving Party in this Action
18 to disobey a lawful directive from another court.
1 | 9, A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
20 PRODUCED IN THIS LITIGATION
21 (a) The terms of this Order are applicable to information produced by a
22 Non-Party in this Action and designated by the Non-Party a Party or as
23 || “CONFIDENTIAL.” Such information produced by Non-Parties in connection with
24 || this litigation is protected by the remedies and relief provided by this Order.
25 Nothing in these provisions should be construed as prohibiting a Non-Party from
26 seeking additional protections.
27 (b) In the event that a Party is required, by a valid discovery request, to
28

produce a Non-Party’s confidential information in its possession, and the Party is
2 subject to an agreement with the Non-Party not to produce the Non-Party’s
3 || confidential information, then the Party shall:
4 (1) promptly notify in writing the Requesting Party and the Non-Party
> || that some or all of the information requested is subject to a confidentiality
6 agreement with a Non-Party;
7 (2) promptly provide the Non-Party with a copy of the Stipulated
8 || Protective Order in this Action, the relevant discovery request(s), and a reasonably
? specific description of the information requested; and
10 (3) make the information requested available for inspection by the
Non-Party, if requested.
12 (c) If the Non-Party fails to seek a protective order from this court within
3 || 14 days of receiving the notice and accompanying information, the Receiving Party
14 may produce the Non-Party’s confidential information responsive to the discovery
I5 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
16 | not produce any information in its possession or control that is subject to the
7 confidentiality agreement with the Non-Party before a determination by the court.
18 || Absent a court order to the contrary, the Non-Party shall bear the burden and
19 expense of seeking protection in this court of its Protected Material.
20 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
21 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
22 || Protected Material to any person or in any circumstance not authorized under this
23 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
24 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
25 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
26 persons to whom unauthorized disclosures were made of all the terms of this Order,
27 |) and (d) request such person or persons to execute the “Acknowledgment and
28

Agreement to Be Bound” that is attached hereto as Exhibit A.
2 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
3 PROTECTED MATERIAL
4 When a Producing Party gives notice to Receiving Parties that certain
5 inadvertently produced material is subject to a claim of privilege or other protection,
6 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
7 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever
8 procedure may be established in an e-discovery order that provides for production
? || without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
10 (e), insofar as the parties reach an agreement on the effect of disclosure of a
11 |) communication or information covered by the attorney-client privilege or work
12 product protection, the parties may incorporate their agreement in the stipulated
13 protective order submitted to the court.
14 12. MISCELLANEOUS
I5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
16 person to seek its modification by the Court in the future.
V7 12.2 Right to Assert Other Objections. By stipulating to the entry of this
18 || Protective Order, no Party waives any right it otherwise would have to object to
19 disclosing or producing any information or item on any ground not addressed in this
20 Stipulated Protective Order. Similarly, no Party waives any right to object on any
21 ground to use in evidence of any of the material covered by this Protective Order.
22 12.3 Filing Protected Material. A Party that seeks to file under seal any
23 || Protected Material must comply with Local Civil Rule 79-5. Protected Material
24 may 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 || in the public record unless otherwise instructed by the court.
28

| 13. FINAL DISPOSITION
2 After the final disposition of this Action, as defined in paragraph 4, within 60
3 days of a written request by the Designating Party, each Receiving Party must return
4 || all Protected Material to the Producing Party or destroy such material. As used in
5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
© || summaries, and any other format reproducing or capturing any of the Protected
7 || Material. Whether the Protected Material is returned or destroyed, the Receiving
8 Party must submit a written certification to the Producing Party (and, if not the same
? person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
10 (by category, where appropriate) all the Protected Material that was returned or
destroyed and (2) affirms that the Receiving Party has not retained any copies,
12 |! abstracts, compilations, summaries or any other format reproducing or capturing any
13 | of the Protected Material. Notwithstanding this provision, Counsel are entitled to
14 |! retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
I5 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
16 reports, attorney work product, and consultant and expert work product, even if such
17 || materials contain Protected Material. Any such archival copies that contain or
18 || constitute Protected Material remain subject to this Protective Order as set forth in
19 || Section 4 (DURATION).
20 || 14. VIOLATION
21 Any violation of this Order may be punished by appropriate measures including,
22 || without limitation, contempt proceedings and/or monetary sanctions.
23
24
29 //
26
27
28

! || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2
3 Dated: August 26, 2025 By: /s/David Shein
Stephen M. Doniger
4 David Shein
5 DONIGER / BURROUGHS
Attorneys for Plaintiff
6
4 Dated: August 26, 2025 By: /s/ Steven P. Mandell
Steven P. Mandell
8 Attorneys for Defendants
9
10 The filer attests that all signatories listed, and on whose behalf this filing is

4 submitted, concur in this filing’s content and have authorized its filing.
12
!3 | FOR GOOD CAUSE SHOWN, THE JOINT MOTION FOR STIPULATED
'4 || PROTECTIVE ORDER IS GRANTED AND IT IS SO ORDERED.
15 .
16 || DATED: August 27, 2025 Raped ln a, OC.
7 Hon. Kozella A. Oliver
United States Magistrate Judge
18
19
20
21
22
23
24
25
26
27
28

EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, [full name], of
5 [full address], declare under penalty of perjury that I have read in its entirety and
6 || understand the Stipulated Protective Order that was issued by the United States
7 || District Court for the Central District of California on [date] in the case of Howard
8 || Schatz, et al. v. Live Auctioneers, LLC, et al., Case No. CV 24-9963-MWF(RAOx).
9 I agree to comply with and to be bound by all the terms of this Stipulated Protective
10 Order and I understand and acknowledge that failure to so comply could expose me
11 || to sanctions and punishment in the nature of contempt. I solemnly promise that I
12 || will not disclose in any manner any information or item that is subject to this
13 Stipulated Protective Order to any person or entity except in strict compliance with
14 the provisions of this Order.
13 | | further agree to submit to the jurisdiction of the United States District Court for the
16 || Central District of California for the purpose of enforcing the terms of this
V7 Stipulated Protective Order, even if such enforcement proceedings occur after
18 | termination of this action. I hereby appoint [full
19 || name] of [full address and
20 telephone number] as my California agent for service of process in connection with
21 || this action or any proceedings related to enforcement of this Stipulated Protective
22 || Order.
23
24 || Date:
2 City and State where signed:
26
Printed name:
27
28 || Signature:

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11131086. Public record. Not legal advice.