Opinion

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8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10 WESTERN DIVISION

11 CLEOTILDE MONTALVO, an Case No. 2:25−cv−02742-SSC

individual,

12 STIPULATED PROTECTIVE

Plaintiff, ORDER

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v. Complaint Filed: February 18, 2025

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NISSAN NORTH AMERICA, INC., a Date:

15 Delaware Corporation, and DOES 1 Time:

through 10, inclusive,

16 District Judge: Anne Hwang

Defendants.

17 Magistrate: Stephanie S.

Christensen

18 Trial Date: Not Set

19 1. INTRODUCTION

20 1.1 Purposes and Limitations. Discovery in this action is likely to

21 involve production of confidential, proprietary, or private information for

22 which special protection from public disclosure and from use for any

23 purpose other than prosecuting this litigation may be warranted.

24 Accordingly, the parties hereby stipulate to and petition the court to enter

25 the following Stipulated Protective Order. The parties acknowledge that

26 this Order does not confer blanket protections on all disclosures or

27 responses to discovery and that the protection it affords from public

28 disclosure and use extends only to the limited information or items that

1 are entitled to confidential treatment under the applicable legal principles.

2 1.2 Good Cause Statement.

3 This action is likely to involve trade secrets, customer and pricing

4 lists and other valuable research, development, commercial, financial,

5 technical and/or proprietary information for which special protection from

6 public disclosure and from use for any purpose other than prosecution of

7 this action is warranted. Such confidential and proprietary materials and

8 information consist of, among other things, confidential business or

9 financial information, information regarding confidential business

10 practices, or other confidential research, development, or commercial

11 information (including information implicating privacy rights of third

12 parties), information otherwise generally unavailable to the public, or

13 which may be privileged or otherwise protected from disclosure under

14 state or federal statutes, court rules, case decisions, or common law.

15 Accordingly, to expedite the flow of information, to facilitate the prompt

16 resolution of disputes over confidentiality of discovery materials, to

17 adequately protect information the parties are entitled to keep

18 confidential, to ensure that the parties are permitted reasonable necessary

19 uses of such material in preparation for and in the conduct of trial, to

20 address their handling at the end of the litigation, and serve the ends of

21 justice, a protective order for such information is justified in this matter.

22 It is the intent of the parties that information will not be designated as

23 confidential for tactical reasons and that nothing be so designated without

24 a good faith belief that it has been maintained in a confidential, non-public

25 manner, and there is good cause why it should not be part of the public

26 record of this case.

27 1.3 Acknowledgment of Procedure for Filing Under Seal. The

28 parties further acknowledge, as set forth in Section 12.3, below, that this

1 Stipulated Protective Order does not entitle them to file confidential

2 information under seal; Local Rule 79-5 sets forth the procedures that

3 must be followed and the standards that will be applied when a party

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

5 There is a strong presumption that the public has a right of access

6 to judicial proceedings and records in civil cases. In connection with non-

7 dispositive motions, good cause must be shown to support a filing under

8 seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176

9 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307

10 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony Elecs., Inc.,

11 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

12 require good cause showing), and a specific showing of good cause or

13 compelling reasons with proper evidentiary support and legal

14 justification, must be made with respect to Protected Material that a

15 party seeks to file under seal. The parties’ mere designation of Disclosure

16 or Discovery Material as CONFIDENTIAL does not—without the

17 submission of competent evidence by declaration, establishing that the

18 material sought to be filed under seal qualifies as confidential, privileged,

19 or otherwise protectable—constitute good cause.

20 Further, if a party requests sealing related to a dispositive motion

21 or trial, then compelling reasons, not only good cause, for the sealing

22 must be shown, and the relief sought shall be narrowly tailored to serve

23 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,

24 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of

25 information, document, or thing sought to be filed or introduced under

26 seal in connection with a dispositive motion or trial, the party seeking

27 protection must articulate compelling reasons, supported by specific facts

28 and legal justification, for the requested sealing order. Again, competent

1 evidence supporting the application to file documents under seal must be

2 provided by declaration.

3 Any document that is not confidential, privileged, or otherwise

4 protectable in its entirety will not be filed under seal if the confidential

5 portions can be redacted. If documents can be redacted, then a redacted

6 version for public viewing, omitting only the confidential, privileged, or

7 otherwise protectable portions of the document, shall be filed. Any

8 application that seeks to file documents under seal in their entirety

9 should include an explanation of why redaction is not feasible.

10 2. DEFINITIONS

11 2.1 Action: Case Number Case No. 2:25−cv−02742-SSC pending in

12 the United States District Court Central District of California Western

13 Division

14 2.2 Challenging Party: a Party or Non-Party that challenges the

15 designation of information or items under this Order.

16 2.3 “CONFIDENTIAL” Information or Items: information

17 (regardless of how it is generated, stored or maintained) or tangible things

18 that qualify for protection under Rule 26(c) of the Federal Rules of Civil

19 Procedure, and as specified above in the Good Cause Statement.

20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well

21 as their support staff).

22 2.5 Designating Party: a Party or Non-Party that designates

23 information or items that it produces in disclosures or in responses to

24 discovery as “CONFIDENTIAL.”

25 2.6 Disclosure or Discovery Material: all items or information,

26 regardless of the medium or manner in which it is generated, stored, or

27 maintained (including, among other things, testimony, transcripts, and

28 tangible things), that are produced or generated in disclosures or

1 responses to discovery in this matter.

2 2.7 Expert: a person with specialized knowledge or experience in a

3 matter pertinent to the litigation who has been retained by a Party or its

4 counsel to serve as an expert witness or as a consultant in this Action.

5 2.8 Final Disposition: the later of (1) dismissal of all claims and

6 defenses in this Action, with or without prejudice; and (2) final judgment

7 herein after the completion and exhaustion of all appeals, rehearings,

8 remands, trials, or reviews of this Action, including the time limits for

9 filing any motions or applications for extension of time pursuant to

10 applicable law.

11 2.9 In-House Counsel: attorneys who are employees of a party to

12 this Action. In-House Counsel does not include Outside Counsel of Record

13 or any other outside counsel.

14 2.10 Non-Party: any natural person, partnership, corporation,

15 association, or other legal entity not named as a Party to this action.

16 2.11 Outside Counsel of Record: attorneys who are not employees of

17 a party to this Action but are retained to represent or advise a party to

18 this Action and have appeared in this Action on behalf of that party or are

19 affiliated with a law firm which has appeared on behalf of that party, and

20 includes support staff.

21 2.12 Party: any party to this Action, including all of its officers,

22 directors, employees, consultants, retained experts, and Outside Counsel

23 of Record (and their support staffs).

24 2.13 Producing Party: a Party or Non-Party that produces

25 Disclosure or Discovery Material in this Action.

26 2.14 Professional Vendors: persons or entities that provide

27 litigation- support services (e.g., photocopying, videotaping, translating,

28 preparing exhibits or demonstrations, and organizing, storing, or

1 retrieving data in any form or medium) and their employees and

2 subcontractors.

3 2.15 Protected Material: any Disclosure or Discovery Material that

4 is designated as “CONFIDENTIAL.”

5 2.16 Receiving Party: a Party that receives Disclosure or Discovery

6 Material from a Producing Party.

7 3. SCOPE

8 The protections conferred by this Stipulation and Order cover not

9 only Protected Material (as defined above), but also (1) any information

10 copied or extracted from Protected Material; (2) all copies, excerpts,

11 summaries, or compilations of Protected Material; and (3) any testimony,

12 conversations, or presentations by Parties or their Counsel that might

13 reveal Protected Material.

14 Any use of Protected Material at trial shall be governed by the

15 orders of the trial judge. This Stipulated Protective Order does not

16 govern the use of Protected Material at trial.

17 4. TRIAL AND DURATION

18 The terms of this Stipulated Protective Order apply through Final

19 Disposition of the Action.

20 Once a case proceeds to trial, information that was

21 designated as CONFIDENTIAL or maintained pursuant to this

22 Stipulated Protective Order and used or introduced as an exhibit

23 at trial becomes public and will be presumptively available to all

24 members of the public, including the press, unless compelling

25 reasons supported by specific factual findings to proceed

26 otherwise are made to the trial judge in advance of the trial. See

27 Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause”

28 showing for sealing documents produced in discovery from

1 “compelling reasons” standard when merits-related documents

2 are part of court record). Accordingly, for such materials, the

3 terms of this Stipulated Protective Order do not extend beyond

4 the commencement of the trial.

5 Even after Final Disposition of this litigation, the confidentiality

6 obligations imposed by this Stipulated Protective Order shall remain in

7 effect until a Designating Party agrees otherwise in writing or a court

8 order otherwise directs.

9 5. DESIGNATING PROTECTED MATERIAL

10 5.1 Exercise of Restraint and Care in Designating Material for

11 Protection. Each Party or Non-Party that designates information or items

12 for protection under this Order must take care to limit any such

13 designation to specific material that qualifies under the appropriate

14 standards. The Designating Party must designate for protection only

15 those parts of material, documents, items, or oral or written

16 communications that qualify so that other portions of the material,

17 documents, items, or communications for which protection is not

18 warranted are not swept unjustifiably within the ambit of this Order.

19 Mass, indiscriminate, or routinized designations are prohibited.

20 Designations that are shown to be clearly unjustified or that have been

21 made for an improper purpose (e.g., to unnecessarily encumber the case

22 development process or to impose unnecessary expenses and burdens on

23 other parties) may expose the Designating Party to sanctions.

24 If it comes to a Designating Party’s attention that information or

25 items that it designated for protection do not qualify for protection, that

26 Designating Party must promptly notify all other Parties that it is

27 withdrawing the inapplicable designation.

28 5.2 Manner and Timing of Designations. Except as otherwise

1 provided in this Stipulated Protective Order (see, e.g., second paragraph of

2 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or

3 Discovery Material that qualifies for protection under this Stipulated

4 Protective Order must be clearly so designated before the material is

5 disclosed or produced.

6 Designation in conformity with this Stipulated Protective Order

7 requires:

8 (a) for information in documentary form (e.g., paper or electronic

9 documents, but excluding transcripts of depositions or other pretrial or

10 trial proceedings), that the Producing Party affix at a minimum, the

11 legend “CONFIDENTIAL” to each page that contains protected material.

12 If only a portion or portions of the material on a page qualifies for

13 protection, the Producing Party also must clearly identify the protected

14 portion(s) (e.g., by making appropriate markings in the margins).

15 A Party or Non-Party that makes original documents available for

16 inspection need not designate them for protection until after the

17 inspecting Party has indicated which documents it would like copied and

18 produced. During the inspection and before the designation, all of the

19 material made available for inspection shall be deemed CONFIDENTIAL.

20 After the inspecting Party has identified the documents it wants copied

21 and produced, the Producing Party must determine which documents, or

22 portions thereof, qualify for protection under this Stipulated Protective

23 Order. Then, before producing the specified documents, the Producing

24 Party must affix the “CONFIDENTIAL” legend to each page that contains

25 Protected Material. If only a portion or portions of the material on a page

26 qualifies for protection, the Producing Party also must clearly identify the

27 protected portion(s) (e.g., by making appropriate markings in the

28 margins).

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

2 identify the Disclosure or Discovery Material on the record, before the

3 close of the deposition all protected testimony.

4 (c) for information produced in some form other than

5 documentary and for any other tangible items, that the Producing Party

6 affix in a prominent place on the exterior of the container or containers in

7 which the information is stored the “CONFIDENTIAL” legend. If only a

8 portion or portions of the information warrants protection, the Producing

9 Party, to the extent practicable, shall identify the protected portion(s).

10 5.3 Inadvertent Failures to Designate. If timely corrected, an

11 inadvertent failure to designate qualified information or items does not,

12 standing alone, waive the Designating Party’s right to secure protection

13 under this Order for such material. Upon timely correction of a

14 designation, the Receiving Party must make reasonable efforts to assure

15 that the material is treated in accordance with the provisions of this

16 Stipulated Protective Order.

17 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

18 6.1 Timing of Challenges. Any Party or Non-Party may challenge

19 a designation of confidentiality at any time that is consistent with the

20 court’s Scheduling Order.

21 6.2 Meet and Confer. The Challenging Party shall initiate the

22 dispute resolution process under Local Rule 37.1 et seq. and with Section

23 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-Discovery

24 Motion Conference.”1

25 6.3 The burden of persuasion in any such challenge proceeding

26 shall be on the Designating Party. Frivolous challenges, and those made

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1 Judge Christensen’s Procedures are available at

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1 for an improper purpose (e.g., to harass or impose unnecessary expenses

2 and burdens on other parties) may expose the Challenging Party to

3 sanctions. Unless the Designating Party has waived or withdrawn the

4 confidentiality designation, all parties shall continue to afford the

5 material in question the level of protection to which it is entitled under

6 the Producing Party’s designation until the court rules on the challenge.

7 7. ACCESS TO AND USE OF PROTECTED MATERIAL

8 7.1 Basic Principles. A Receiving Party may use Protected

9 Material that is disclosed or produced by another Party or by a Non-Party

10 in connection with this Action only for prosecuting, defending, or

11 attempting to settle this Action. Such Protected Material may be

12 disclosed only to the categories of persons and under the conditions

13 described in this Order. When the Action reaches a Final Disposition, a

14 Receiving Party must comply with the provisions of section 13 below.

15 Protected Material must be stored and maintained by a Receiving

16 Party at a location and in a secure manner that ensures that access is

17 limited to the persons authorized under this Stipulated Protective Order.

18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

19 otherwise ordered by the court or permitted in writing by the Designating

20 Party, a Receiving Party may disclose any information or item designated

21 “CONFIDENTIAL” only:

22 (a) to the Receiving Party’s Outside Counsel of Record in this

23 Action, as well as employees of said Outside Counsel of Record to whom it

24 is reasonably necessary to disclose the information for this Action;

25 (b) to the officers, directors, and employees (including House

26 Counsel) of the Receiving Party to whom disclosure is reasonably

27 necessary for this Action;

28 (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 this

7 Action and who have signed the “Acknowledgment and Agreement to Be

8 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 unless

17 they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A),

18 unless otherwise agreed by the Designating Party or ordered by the court.

19 Pages of transcribed deposition testimony or exhibits to depositions that

20 reveal Protected Material may be separately bound by the court reporter

21 and may not be disclosed to anyone except as permitted under this

22 Stipulated Protective Order; and

23 (i) to any mediator or settlement officer, and their supporting

24 personnel, mutually agreed upon by any of the parties engaged in

25 settlement discussions.

26 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

27 PRODUCED IN OTHER LITIGATION

28 If a Party is served with a subpoena or a court order issued in other

1 litigation that compels disclosure of any information or items designated

2 in this Action as “CONFIDENTIAL,” that Party must:

3 (a) promptly notify in writing the Designating Party. Such

4 notification shall include a copy of the subpoena or court order;

5 (b) promptly notify in writing the party who caused the subpoena

6 or order to issue in the other litigation that some or all of the material

7 covered by the subpoena or order is subject to this Protective Order. Such

8 notification shall include a copy of this Stipulated Protective Order; and

9 (c) cooperate with respect to all reasonable procedures sought to

10 be pursued by the Designating Party whose Protected Material may be

11 affected.

12 If the Designating Party timely seeks a protective order, the

13 Party served with the subpoena or court order shall not produce any

14 information designated in this action as “CONFIDENTIAL” before a

15 determination by the court from which the subpoena or order issued,

16 unless the Party has obtained the Designating Party’s permission. The

17 Designating Party shall bear the burden and expense of seeking

18 protection in that court of its confidential material and nothing in these

19 provisions should be construed as authorizing or encouraging a Receiving

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

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

28 construed as prohibiting a Non-Party from seeking additional protections.

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 the

10 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 10. UNAUTHORIZED DISCLOSURE OF PROTECTED

22 MATERIAL

23 If a Receiving Party learns that, by inadvertence or otherwise, it has

24 disclosed Protected Material to any person or in any circumstance not

25 authorized under this Stipulated Protective Order, the Receiving Party

26 must immediately (a) notify in writing the Designating Party of the

27 unauthorized disclosures, (b) use its best efforts to retrieve all

28 unauthorized copies of the Protected Material, (c) inform the person or

1 persons to whom unauthorized disclosures were made of all the terms of

2 this Order, and (d) request such person or persons to execute the

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

4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR

5 OTHERWISE PROTECTED MATERIAL

6 When a Producing Party gives notice to Receiving Parties that

7 certain inadvertently produced material is subject to a claim of privilege

8 or other protection, the obligations of the Receiving Parties are those set

9 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This

10 provision is not intended to modify whatever procedure may be

11 established in an e-discovery order that provides for production without

12 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal

13 Rules of Evidence, insofar as the parties reach an agreement on the effect

14 of disclosure of a communication or information covered by the attorney-

15 client privilege or work product protection, the parties may incorporate

16 their agreement in the stipulated protective order submitted to the court.

17 12. MISCELLANEOUS

18 12.1 Right to Further Relief. Nothing in this Stipulated Protective

19 Order abridges the right of any person to seek its modification by the

20 court in the future.

21 12.2 Right to Assert Other Objections. By stipulating to the entry

22 of this Stipulated Protective Order no Party waives any right it otherwise

23 would have to object to disclosing or producing any information or item on

24 any ground not addressed in this Stipulated Protective Order. Similarly,

25 no Party waives any right to object on any ground to use in evidence of

26 any of the material covered by this Stipulated Protective Order.

27 12.3 Filing Protected Material. A Party that seeks to file under

28 seal any Protected Material must comply with Local Rule 79-5. Protected

1 Material may only be filed under seal pursuant to a court order

2 authorizing the sealing of the specific Protected Material at issue. If a

3 Party's request to file Protected Material under seal is denied by the

4 court, then the Receiving Party may file the information in the public

5 record unless otherwise instructed by the court.

6 13. FINAL DISPOSITION

7 After the Final Disposition of this Action, as defined in paragraph 4,

8 within 60 days of a written request by the Designating Party, each

9 Receiving Party must return all Protected Material to the Producing

10 Party or destroy such material. As used in this subdivision, “all Protected

11 Material” includes all copies, abstracts, compilations, summaries, and any

12 other format reproducing or capturing any of the Protected Material.

13 Whether the Protected Material is returned or destroyed, the Receiving

14 Party must submit a written certification to the Producing Party (and, if

15 not the same person or entity, to the Designating Party) by the 60 day

16 deadline that (1) identifies (by category, where appropriate) all the

17 Protected Material that was returned or destroyed and (2) affirms that

18 the Receiving Party has not retained any copies, abstracts, compilations,

19 summaries or any other format reproducing or capturing any of the

20 Protected Material. Notwithstanding this provision, Counsel is entitled to

21 retain an archival copy of all pleadings, motion papers, trial, deposition,

22 and hearing transcripts, legal memoranda, correspondence, deposition

23 and trial exhibits, expert reports, attorney work product, and consultant

24 and expert work product, even if such materials contain Protected

25 Material. Any such archival copies that contain or constitute Protected

26 Material remain subject to this Protective Order as set forth in Section

27 14.VIOLATION

28 Any violation of this Stipulated Protective Order may be punished

1 ||by any and all appropriate measures including, without limitation,

2 ||contempt proceedings and/or monetary sanctions.

3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

4 || Dated: April 27, 2026 QUILL AND ARROW LLP

5

6 By: /s/Andrew Jun

KEVIN Y. JACOBSON

7 ANDREW C. JUNG

Attorneys for Plaintiff

8 CLEOTILDE MONTALVO

9

10 Dated: April 27, 2026 WILSON TURNER KOSMO LLP

11

12 By: /s/ Taylor N. Donoho

13 ROBERT A. SHIELDS

TAYLOR N. DONOHO

14 Attorneys for Defendant

NISSAN NORTH AMERICA, INC.

15

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7 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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19 DATED: April 29, 2026

20 STEPHANIE S. CHRISTENSEN

>] United States Magistrate Judge

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-16- Case No. 2:25-cv—02742-SSC

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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

4 _________________ [print or type full address], declare under penalty

5 of perjury that I have read in its entirety and understand the Stipulated

6 Protective Order that was issued by the United States District Court

7 for the Central District of California on [date] in the case of

8 __________ [Cleotilde Montalvo v. Nissan North America, Inc.

9 2:25−cv−02742-SSC]. I agree to comply with and to be bound by all the

10 terms of this Stipulated Protective Order and I understand and

11 acknowledge that failure to so comply could expose me to sanctions and

12 punishment in the nature of contempt. I solemnly promise that I will

13 not disclose in any manner any information or item that is subject to

14 this Stipulated Protective Order to any person or entity except in strict

15 compliance with the provisions of this Order.

16 I further agree to submit to the jurisdiction of the United States

17 District Court for the Central District of California for the purpose of

18 enforcing the terms of this Stipulated Protective Order, even if such

19 enforcement proceedings occur after termination of this action. I hereby

20 appoint ________________________ [print or type full name] of

21 _________ [print or type full address and telephone number] as

22 my California agent for service of process in connection with this

23 action or any proceedings related to enforcement of this Stipulated

24 Protective Order.

25 Date: ___________________________

26 City and State where sworn and signed: ___________________________

27 Printed name: ___________________________

28 Signature: ___________________________