Opinion

1 ORANGE COUNTY COASTKEEPER

SARAH J. SPINUZZI, SB# 305658

2 E-Mail: sarah@coastkeeper.org

DAVINA SHOUMER, SB# 358336

3 E-Mail: davina@coastkeeper.org

3151 Airway Avenue, Suite F-110

4 Costa Mesa, California 92626

Telephone: 714.850.1965

5

Attorneys for Plaintiffs

6 INLAND EMPIRE WATERKEEPER and

ORANGE COUNTY WATERKEEPER

7

LEWIS BRISBOIS BISGAARD & SMITH LLP

8 JOSEPH A. SALAZAR JR., SB# 169551

E-Mail: Joe.Salazar@lewisbrisbois.com

9 JAY C. PATTERSON, SB# 238829

E-Mail: Jay.Patterson@lewisbrisbois.com

10 2020 West El Camino Avenue, Suite 700

Sacramento, California 95833

11 Telephone: 916.564.5400

Facsimile: 916.564.5444

12

Attorneys for Defendants, AMREP

13 MANUFACTURING COMPANY, LLC ,

WASTEQUIP MANUFACTURING

14 COMPANY, LLC and REXFORD

INDUSTRIAL – 1555 CUCAMONGA, LLC

15 UNITED STATES DISTRICT COURT

16 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

17 INLAND EMPIRE WATERKEEPER, a Case No. 8:25-cv-00998-JVS-DFM

program of Orange County Coastkeeper, and

18 ORANGE COUNTY COASTKEEPER, a STIPULATED PROTECTIVE ORDER

California nonprofit public benefit

19 corporation, Trial Date: March 23, 2027

20 Plaintiffs,

21 vs.

22 AMREP MANUFACTURING COMPANY,

LLC, a Limited Liability Company;

23 WASTEQUIP MANUFACTURING

COMPANY, LLC, a Limited Liability

24 Company; and REXFORD INDUSTRIAL –

1555 CUCAMONGA, LLC, a Limited

25 Liability Company,

26 Defendants.

27

1 1.1 Purposes and Limitations. Discovery in this action is likely to involve

2 production of confidential, proprietary, or private information for which special protection from

3 public disclosure and from use for any purpose other than prosecuting this litigation may be

4 warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the

5 following Stipulated Protective Order. The parties acknowledge that this Order does not confer

6 blanket protections on all disclosures or responses to discovery and that the protection it affords

7 from public disclosure and use extends only to the limited information or items that are entitled

8 to confidential treatment under the applicable legal principles.

9 1.2 Good Cause Statement.

10 This action is likely to involve confidential financial information regarding a private

11 corporation for which special protection from public disclosure and from use for any purpose other

12 than prosecution of this action is warranted. Such confidential and proprietary materials and

13 information consist of, among other things, private financial statements detailing the assets,

14 liabilities, revenues, profitability, and other information. While such information may be

15 discoverable in a Clean Water Act action like this one, it is generally unavailable to the public, and

16 may be privileged or otherwise protected from disclosure under state or federal statutes, court

17 rules, case decisions, or common law. Public disclosure of such information may be highly

18 prejudicial to Defendants.

19 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of

20 disputes over confidentiality of discovery materials, to adequately protect information the parties are

21 entitled to keep confidential, to ensure that the parties are permitted reasonable necessary uses of

22 such material in preparation 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 information is justified in this

24 matter. It is the intent of the parties that information will not be designated as confidential for

25 tactical reasons and that nothing be so designated without a good faith belief that it has been

26 maintained in a confidential, nonpublic manner, and there is good cause why it should not be part of

27 the public record of this case.

1 The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated

2 Protective Order does not entitle them to file confidential information under seal; Local Rule 79-

3 5 sets forth the procedures that must be followed and the standards that will be applied when a

4 party seeks permission from the court to file material under seal.

5 There is a strong presumption that the public has a right of access to judicial proceedings and

6 records in civil cases. In connection with non-dispositive motions, good cause must be shown to

7 support a filing under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th

8 Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir.

9 2002), Makar-Welbon v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated

10 protective orders require good cause showing), and a specific showing of good cause or compelling

11 reasons with proper evidentiary support and legal justification, must be made with respect to

12 Protected Material that a party seeks to file under seal. The parties’ mere designation of Disclosure

13 or Discovery Material as CONFIDENTIAL does not—without the submission of competent

14 evidence by declaration, establishing that the material sought to be filed under seal qualifies as

15 confidential, privileged, or otherwise protectable—constitute good cause.

16 Further, if a party requests sealing related to a dispositive motion or trial, then

17 compelling reasons, not only good cause, for the sealing must be shown, and the relief sought

18 shall be narrowly tailored to serve the specific interest to be protected. See Pintos v. Pac.

19 Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of information,

20 document, or thing sought to be filed or introduced under seal in connection with a dispositive

21 motion or trial, the party seeking protection must articulate compelling reasons, supported by

22 specific facts and legal justification, for the requested sealing order. Again, competent evidence

23 supporting the application to file documents under seal must be provided by declaration.

24 Any document that is not confidential, privileged, or otherwise protectable in its entirety

25 will not be filed under seal if the confidential portions can be redacted. If documents can be

26 redacted, then a redacted version for public viewing, omitting only the confidential, privileged, or

27 otherwise protectable portions of the document, shall be filed. Any application that seeks to file

1 feasible.

2 2. DEFINITIONS

3 2.1 Action: The above-captioned pending federal lawsuit brought under the Clean

4 Water Act.

5

6 2.2 Challenging Party: a Party or Non-Party that challenges the designation of

7 information or items under this Order.

8 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is

9 generated, stored or maintained) or tangible things that qualify for protection under Rule 26(c) of

10 the Federal Rules of Civil Procedure, and as specified above in the Good Cause Statement.

11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

12 support staff).

13 2.5 Designating Party: a Party or Non-Party that designates information or items that

14 it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

15 2.6 Disclosure or Discovery Material: all items or information, regardless of the

16 medium or manner in which it is generated, stored, or maintained (including, among other things,

17 testimony, transcripts, and tangible things), that are produced or generated in disclosures or

18 responses to discovery in this matter.

19 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to

20 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a

21 consultant in this Action.

22 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in this

23 Action, with or without prejudice; and (2) final judgment herein after the completion and

24 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, including the time

25 limits for filing any motions or applications for extension of time pursuant to applicable law.

26 2.9 In-House Counsel: attorneys who are employees of a party to this Action. In-

27 House Counsel does not include Outside Counsel of Record or any other outside counsel.

1 entity not named as a Party to this action.

2 2.11 Outside Counsel of Record: attorneys who are not employees of a party to this

3 Action but are retained to represent or advise a party to this Action and have appeared in this

4 Action on behalf of that party or are affiliated with a law firm which has appeared on behalf of

5 that party, and includes support staff.

6 2.12 Party: any party to this Action, including all of its officers, directors, employees,

7 consultants, retained experts, and Outside Counsel of Record (and their support staffs).

8 2.13 Producing Party: a Party or Non-Party that produces Disclosure or Discovery

9 Material in this Action.

10 2.14 Professional Vendors: persons or entities that provide litigation- support services

11 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and

12 organizing, storing, or retrieving data in any form or medium) and their employees and

13 subcontractors.

14 2.15 Protected Material: any Disclosure or Discovery Material that is designated as

15 “CONFIDENTIAL.”

16 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material

17 from a Producing Party.

18 3. SCOPE

19 The protections conferred by this Stipulation and Order cover not only Protected Material

20 (as defined above), but also (1) any information copied or extracted from Protected Material; (2)

21 all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,

22 conversations, or presentations by Parties or their Counsel that might reveal Protected Material.

23 Any use of Protected Material at trial shall be governed by the orders of the trial judge.

24 This Stipulated Protective Order does not govern the use of Protected Material at trial.

25 4. TRIAL AND DURATION

26 The terms of this Stipulated Protective Order apply through Final Disposition of the Action.

27 Once a case proceeds to trial, information that was designated as CONFIDENTIAL or

1 becomes public and will be presumptively available to all members of the public, including the

2 press, unless compelling reasons supported by specific factual findings to proceed otherwise are

3 made to the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing

4 “good cause” showing for sealing documents produced in discovery from “compelling reasons”

5 standard when merits-related documents are part of court record). Accordingly, for such materials,

6 the terms of this Stipulated Protective Order do not extend beyond the commencement of the trial.

7 Even after Final Disposition of this litigation, the confidentiality obligations imposed by

8 this Stipulated Protective Order shall remain in effect until a Designating Party agrees otherwise in

9 writing or a court order otherwise directs.

10 5. DESIGNATING PROTECTED MATERIAL

11 5.1 Exercise of Restraint and Care in Designating Material for Protection.

12 Each Party or Non-Party that designates information or items for protection under this

13 Order must take care to limit any such designation to specific material that qualifies under the

14 appropriate standards. The Designating Party must designate for protection only those parts of

15 material, documents, items, or oral or written communications that qualify so that other portions of

16 the material, documents, items, or communications for which protection is not warranted are not

17 swept unjustifiably within the ambit of this Order.

18 Mass, indiscriminate, or routinized designations are prohibited. Designations that are

19 shown to be clearly unjustified or that have been made for an improper purpose (e.g., to

20 unnecessarily encumber the case development process or to impose unnecessary expenses and

21 burdens on other parties) may expose the Designating Party to sanctions.

22 If it comes to a Designating Party’s attention that information or items that it designated

23 for protection do not qualify for protection, that Designating Party must promptly notify all

24 other Parties that it is withdrawing the inapplicable designation.

25 5.2 Manner and Timing of Designations.

26 Except as otherwise provided in this Stipulated Protective Order (see, e.g., second

27 paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or

1 clearly so designated before the material is disclosed or produced.

2 Designation in conformity with this Stipulated Protective Order requires:

3 (a) for information in documentary form (e.g., paper or electronic documents, but

4 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing

5 Party affix at a minimum, the legend “CONFIDENTIAL” to each page that contains protected

6 material. If only a portion or portions of the material on a page qualifies for protection, the

7 Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate

8 markings in the margins).

9 A Party or Non-Party that makes original documents available for inspection need not

10 designate them for protection until after the inspecting Party has indicated which documents it

11 would like copied and produced. During the inspection and before the designation, all of the

12 material made available for inspection shall be deemed CONFIDENTIAL. After the inspecting

13 Party has identified the documents it wants copied and produced, the Producing Party must

14 determine which documents, or portions thereof, qualify for protection under this Stipulated

15 Protective Order. Then, before producing the specified documents, the Producing Party must affix

16 the “CONFIDENTIAL” legend to each page that contains Protected Material. If only a portion or

17 portions of the material on a page qualifies for protection, the Producing Party also must clearly

18 identify the protected portion(s) (e.g., by making appropriate markings in the margins).

19 (b) for testimony given in depositions that the Designating Party identify the

20 Disclosure or Discovery Material on the record, before the close of the deposition all protected

21 testimony.

22 (c) for information produced in some form other than documentary and for any other

23 tangible items, that the Producing Party affix in a prominent place on the exterior of the container

24 or containers in which the information is stored the “CONFIDENTIAL” legend. If only a portion

25 or portions of the information warrants protection, the Producing Party, to the extent practicable,

26 shall identify the protected portion(s).

27 5.3 Inadvertent Failures to Designate.

1 not, standing alone, waive the Designating Party’s right to secure protection under this Order for

2 such material. Upon timely correction of a designation, the Receiving Party must make reasonable

3 efforts to assure that the material is treated in accordance with the provisions of this Stipulated

4 Protective Order.

5 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

6 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of

7 confidentiality at any time that is consistent with the court’s Scheduling Order.

8 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution

9 process under Local Rule 37-1 et seq. and with Section 3 of Judge McCormick’s Procedures titled

10 “Informal Telephonic Conference in Discovery Disputes.”1

11 6.3 The burden of persuasion in any such challenge proceeding shall be on the

12 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass

13 or impose unnecessary expenses and burdens on other parties) may expose the Challenging Party

14 to sanctions. Unless the Designating Party has waived or withdrawn the confidentiality

15 designation, all parties shall continue to afford the material in question the level of protection to

16 which it is entitled under the Producing Party’s designation until the court rules on the challenge.

17 7. ACCESS TO AND USE OF PROTECTED MATERIAL

18 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or

19 produced by another Party or by a Non-Party in connection with this Action only for prosecuting,

20 defending, or attempting to settle this Action. Such Protected Material may be disclosed only to

21 the categories of persons and under the conditions described in this Order. When the Action

22 reaches a Final Disposition, a Receiving Party must comply with the provisions of section 13

23 below.

24 Protected Material must be stored and maintained by a Receiving Party at a location and in

25 a secure manner that ensures that access is limited to the persons authorized under this Stipulated

26

27

1 Judge McCormick’s procedures are available at https://apps.cacd.uscourts.gov/Jps/honorable-douglas-f-

1 Protective Order.

2 7.2 Disclosure of “CONFIDENTIAL” Information or Items.

3 Unless otherwise ordered by the court or permitted in writing by the Designating Party, a

4 Receiving Party may disclose any information or item designated “CONFIDENTIAL” only:

5 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as well as

6 employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the

7 information for this Action;

8 (b) to the officers, directors, and employees (including House Counsel) of the

9 Receiving Party to whom disclosure is reasonably necessary for this Action;

10 (c) to Experts (as defined in this Order) of the Receiving Party to whom disclosure is

11 reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement

12 to Be Bound” (Exhibit A);

13 (d) to the court and its personnel;

14 (e) to court reporters and their staff;

15 (f) to professional jury or trial consultants, mock jurors, and Professional Vendors to

16 whom disclosure is reasonably necessary for this Action and who have signed the

17 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

18 (g) to the author or recipient of a document containing the information or a custodian

19 or other person who otherwise possessed or knew the information;

20 (h) during their depositions, to witnesses, and attorneys for witnesses, in the Action to

21 whom disclosure is reasonably necessary, provided: (1) the deposing party requests that the

22 witness sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the

23 witness will not be permitted to keep any confidential information unless they sign the

24 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the

25 Designating Party or ordered by the court. Pages of transcribed deposition testimony or exhibits

26 to depositions that reveal Protected Material may be separately bound by the court reporter and

27 may not be disclosed to anyone except as permitted under this Stipulated Protective Order; and

1 agreed upon by any of the parties engaged in settlement discussions.

2

3

4

5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

6 OTHER LITIGATION

7 If a Party is served with a subpoena or a court order issued in other litigation that compels

8 disclosure of any information or items designated in this Action as “CONFIDENTIAL,” that

9 Party must:

10 (a) promptly notify in writing the Designating Party. Such notification shall include a

11 copy of the subpoena or court order;

12 (b) promptly notify in writing the party who caused the subpoena or order to issue in

13 the other litigation that some or all of the material covered by the subpoena or order is subject to

14 this Protective Order. Such notification shall include a copy of this Stipulated Protective Order;

15 and

16 (c) cooperate with respect to all reasonable procedures sought to be pursued by the

17 Designating Party whose Protected Material may be affected.

18 If the Designating Party timely seeks a protective order, the Party served with the

19 subpoena or court order shall not produce any information designated in this action as

20 “CONFIDENTIAL” before a determination by the court from which the subpoena or order

21 issued, unless the Party has obtained the Designating Party’s permission. The Designating Party

22 shall bear the burden and expense of seeking protection in that court of its confidential material

23 and nothing in these provisions should be construed as authorizing or encouraging a Receiving

24 Party in this Action to disobey a lawful directive from another court.

25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN

26 THIS LITIGATION

27 9.1 Application. The terms of this Stipulated Protective Order are applicable to

1 information produced by Non-Parties in connection with this litigation is protected by the

2 remedies and relief provided by this Order. Nothing in these provisions should be construed as

3 prohibiting a Non-Party from seeking additional protections.

4 9.2 Notification. In the event that a Party is required, by a valid discovery request, to

5 produce a Non-Party’s confidential information in its possession, and the Party is subject to an

6 agreement with the Non-Party not to produce the Non-Party’s confidential information, then the

7 Party shall:

8 (a) promptly notify in writing the Requesting Party and the Non-Party that some or all of

9 the information requested is subject to a confidentiality agreement with a Non-Party;

10 (b) make the information requested available for inspection by the Non-Party, if

11 requested.

12 9.3 Conditions of Production. If the Non-Party fails to seek a protective order from

13 this court within 14 days of receiving the notice and accompanying information, the Receiving

14 Party may produce the Non-Party’s confidential information responsive to the discovery request.

15 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce any

16 information in its possession or control that is subject to the confidentiality agreement with the

17 Non-Party before a determination by the court. Absent a court order to the contrary, the Non-

18 Party shall bear the burden and expense of seeking protection in this court of its Protected

19 Material.

20 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

21 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected

22 Material to any person or in any circumstance not authorized under this Stipulated Protective

23 Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the

24 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the

25 Protected Material, (c) inform the person or persons to whom unauthorized disclosures were

26 made of all the terms of this Order, and (d) request such person or persons to execute the

27 “Acknowledgment and Agreement to Be Bound” (Exhibit A).

1 PROTECTED MATERIAL

2 When a Producing Party gives notice to Receiving Parties that certain inadvertently

3 produced material is subject to a claim of privilege or other protection, the obligations of the

4 Receiving Parties are those set forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure.

5 This provision is not intended to modify whatever procedure may be established in an e-

6 discovery order that provides for production without prior privilege review. Pursuant to Rules

7 502(d) and (e) of the Federal Rules of Evidence, insofar as the parties reach an agreement on the

8 effect of disclosure of a communication or information covered by the attorney-client privilege or

9 work product protection, the parties may incorporate their agreement in the stipulated protective

10 order submitted to the court.

11 12. MISCELLANEOUS

12 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order abridges the

13 right of any 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 Stipulated

15 Protective Order no Party waives any right it otherwise would have to object to disclosing or

16 producing any information or item on any ground not addressed in this Stipulated Protective

17 Order. Similarly, no Party waives any right to object on any ground to use in evidence of any of

18 the material covered by this Stipulated Protective Order.

19 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected

20 Material must comply with Local Rule 79-5. Protected Material may only be filed under seal

21 pursuant to a court order authorizing the sealing of the specific Protected Material at issue. If a

22 Party's request to file Protected Material under seal is denied by the court, then the Receiving

23 Party may file the information in the public record unless otherwise instructed by the court.

24 13. FINAL DISPOSITION

25 After the Final Disposition of this Action, as defined in paragraph 4, within 60 days of a

26 written request by the Designating Party, each Receiving Party must return all Protected Material

27 to the Producing Party or destroy such material. As used in this subdivision, “all Protected

] || reproducing or capturing any of the Protected Material. Whether the Protected Material is

2 || returned or destroyed, the Receiving Party must submit a written certification to the Producing

3 || Party (and, if not the same person or entity, to the Designating Party) by the 60 day deadline that

4 || (1) identifies (by category, where appropriate) all the Protected Material that was returned or

5 || destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts,

6 || compilations, summaries or any other format reproducing or capturing any of the Protected

7 || Material. Notwithstanding this provision, Counsel is entitled to retain an archival copy of all

8 || pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,

9 || correspondence, deposition and trial exhibits, expert reports, attorney work product, and

10 || consultant and expert work product, even if such materials contain Protected Material. Any such

11 || archival copies that contain or constitute Protected Material remain subject to this Protective

12 || Order as set forth in Section 4.

13 |}14. VIOLATION

14 Any violation of this Stipulated Protective Order may be punished by any and all

15 || appropriate measures including, without limitation, contempt proceedings and/or monetary

16 || sanctions.

17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

18 || DATED: March __, 2026

SARAH SPINUZZI

19 Attorneys for Plaintiffs

INLAND EMPIRE WATERKEEPER and

20 ORANGE COUNTY WATERKEEPER

21||DATED: March __, 2026

JAY C. PATTERSON

22 Attorneys for Defendants

AMREP MANUFACTURING COMPANY, LLC ,

23 WASTEQUIP MANUFACTURING COMPANY,

LLC and REXFORD INDUSTRIAL — 1555

24 CUCAMONGA, LLC

25 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

26

DATED:_ March 25, 2026 +

27 F. McCeérrftic

Unite States Magistrate Judge

28

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, ________________________ [print or type full name], of _________________ [print or

4 type full address], declare under penalty of perjury that I have read in its entirety and understand

5 the Stipulated Protective Order that was issued by the United States District Court for the Central

6 District of California on [date] in the case of __________ [insert formal name of the case and the

7 number and initials assigned to it by the court]. I agree to comply with and to be bound by all the

8 terms of this Stipulated Protective Order and I understand and acknowledge that failure to so

9 comply could expose me to sanctions and punishment in the nature of contempt. I solemnly

10 promise that I will not disclose in any manner any information or item that is subject to this

11 Stipulated Protective Order to any person or entity except in strict compliance with the provisions

12 of this Order.

13 I further agree to submit to the jurisdiction of the United States District Court for the

14 Central District of California for the purpose of enforcing the terms of this Stipulated Protective

15 Order, even if such enforcement proceedings occur after termination of this action. I hereby

16 appoint ________________________ [print or type full name] of _________ [print or type full

17 address and telephone number] as

18 my California agent for service of process in connection with this action or any proceedings

19 related to enforcement of this Stipulated Protective Order.

20 Date: ___________________________

21 City and State where sworn and signed: ___________________________

22 Printed name: ___________________________

23 Signature: ___________________________

24

25

26

27