# Segroves

> District Court, E.D. California · March 18, 2026

URL: https://www.frixlaw.com/law-library/cases/11377802

## Case

- **Full name:** Dawn Segroves, et al. v. Jeremy Franchini
- **Court:** District Court, E.D. California
- **Decided:** March 18, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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6 UNITED STATES DISTRICT COURT
7 FOR THE EASTERN DISTRICT OF CALIFORNIA
8
9 DAWN SEGROVES, et al., Case No. 2:25-cv-03076-WBS-CSK
10 Plaintiffs, ORDER GRANTING MODIFIED
STIPULATED PROTECTIVE ORDER
V.
(ECF No. 17)
12 JEREMY FRANCHINI,
13 Defendant.
14
13 The Court has reviewed the parties’ stipulated protective order below (ECF No.

6 17), and finds it comports with the relevant authorities and the Court’s Local Rule. See

L.R. 141.1. The Court APPROVES the protective order, subject to the following
clarification.
18
19 The Court’s Local Rules indicate that once an action is closed, it “will not retain

50 jurisdiction over enforcement of the terms of any protective order filed in that action.”

54 L.R. 141.1(f); see Bylin Heating Sys., Inc. v. Thermal Techs., Inc., 2012 WL 13237584,

> at *2 (E.D. Cal. Oct. 29, 2012) (noting that courts in the district generally do not retain

jurisdiction for disputes concerning protective orders after closure of the case). Thus, the

34 Court will not retain jurisdiction over this protective order once the case is closed.
Dated: March 18, 2026 cy - $ .
CHI SOO KIM
UNITED STATES MAGISTRATE JUDGE
27
4, segr3076.25
28

1 ROB BONTA, State Bar No. 202668
Attorney General of California
2 ELIZABETH S. ANGRES, State Bar No. 179523
Supervising Deputy Attorney General
3 EMILY WILLIAMS, State Bar No. No. 316724
Deputy Attorney General
4 300 South Spring Street, Suite 1702
Los Angeles, CA 90013-1230
5 Telephone: (213) 269-6463
Fax: (916) 731-2120
6 E-mail: Emily.Williams@doj.ca.gov
STEPHANIE A. VOLLMER, State Bar No. 309407
7 Deputy Attorney General
455 Golden Gate Avenue, Suite 11000
8 San Francisco, CA 94102-7004
Telephone: (415) 510-3849
9 Fax: (415) 703-5480
E-mail: Stephanie.Vollmer@doj.ca.gov
10 Attorneys for Defendant Jeremy Franchini

11
IN THE UNITED STATES DISTRICT COURT
12
FOR THE EASTERN DISTRICT OF CALIFORNIA
13

14
15
16 DAWN SEGROVES, INDIVIDUALLY; 2:25-cv-03076-WBS-CSK
AND CAMERON HALL, INDIVIDUALLY
17 AND AS SUCCESSOR-IN-INTEREST TO
THE ESTATE OF HOLLY SEGROVES,
18 STIPULATED PROTECTIVE ORDER
Plaintiffs,
19
v.
20
21 JEREMY FRANCHINI, AN INDIVIDUAL;
AND DOES 1-20, INCLUSIVE,
22
Defendants.
23

24
25
26 1. A. PURPOSES AND LIMITATIONS
27 Discovery in this action is likely to involve production of confidential, proprietary, or
28 private information for which special protection from public disclosure and from use for any
1 purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby
2 stipulate to, and petition the Court to, enter the following Stipulated Protective Order. The parties
3 acknowledge that this Order does not confer blanket protections on all disclosures or responses to
4 discovery and that the afforded protection from public disclosure and use extends only to the
5 limited information, or items, entitled to confidential treatment under applicable legal principles.
6 The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated
7 Protective Order does not entitle them to file confidential information under seal; Civil Local
8 Rule 141 sets forth the procedures that must be followed, and the standards that will be applied,
9 when a party seeks permission from the court to file material under seal.
10 B. GOOD CAUSE STATEMENT
11 Defendant California Highway Patrol Officer Jeremy Franchini (Officer Franchini) may
12 be producing documents that contain information generally unavailable to the public, and/or
13 information privileged, or otherwise protected, from disclosure under federal or state statues,
14 court rules, judicial decisions, or common law. Officer Franchini may produce documents
15 containing information concerning confidential, internal policies of the State of California acting
16 by and through the California Highway Patrol (CHP), and said documents are generally not
17 available to the public. The disclosure of this information may jeopardize the security of CHP’s
18 operations and jeopardize the safety of peace officers. Officer Franchini may also produce
19 documents containing personal and confidential information about individuals, and such
20 information is generally not available to the public. This information includes peace officer
21 personnel records and records related to third parties. The disclosure of this information to the
22 public may violate the privacy rights of those individuals. Officer Franchini may also produce
23 video, audio, and still photo images related to the subject matter at issue in this case, and such
24 information is generally unavailable to the public. Additionally, Officer Franchini may produce
25 investigation reports, not generally available to the public, the disclosure of which could violate
26 the privacy rights of individuals and could jeopardize the safety of peace officers. Also,
27 documents to be produced pursuant to a subpoena, for example, will likely include autopsy
28 photographs, which California Code of Civil Procedure section 129 prohibits disseminating.
1 Therefore, as it relates to the case at bar, a protective order is warranted for the following
2 reasons: to expedite an information flow; to facilitate prompt resolution of disputes about the
3 confidentiality of discovery materials; to protect adequately information that parties are entitled to
4 keep confidential; to ensure that parties have reasonable, necessary use(s) of sensitive material so
5 they can prepare for and conduct a trial; to address the handling of such information at litigation’s
6 end; and, to ensure that justice is served. It is the parties’ intent that information will not be
7 designated as confidential purely for tactical reasons, and that no information will be designated
8 without a good-faith belief that said information has been maintained in a confidential, non-public
9 manner, and that there is good cause for why it should refrain from being included within the
10 public record of this case.
11 2. DEFINITIONS
12 2.1 Action: Dawn Segroves, individually; and Cameron Hall, individually, and as
13 successor-in-interest to the estate of Holly Segroves v. Jeremy Franchini et al., United States
14 District Court for the Eastern District of California, Case Number 2:25-cv-03076-WBS-CSK.
15 2.2 Challenging Party: a Party, or Non-Party, who challenges the designation of
16 information or items pursuant to this Order.
17 2.3 “CONFIDENTIAL” Information or Items: information (regardless of the manner in
18 which it is generated, stored, or maintained) or tangible things that qualify for protection under
19 Federal Rule of Civil Procedure 26(c) and as specified above in the Good Cause Statement.
20 2.4 Counsel: Outside Counsel of Record and House Counsel (along with their support
21 staff).
22 2.5 Designating Party: a Party, or Non-Party, who designates as “CONFIDENTIAL”
23 information or items that they produce in disclosures or in response to discovery.
24 2.6 Disclosure or Discovery Material: all items or information, regardless of the medium
25 or manner in which it is generated, stored, or maintained (including, among other things,
26 testimony, transcripts, and tangible things), which are produced or generated in disclosures or in
27 responses to discovery in this matter.
28 2.7 Expert: a person with specialized knowledge or experience, in a matter pertinent to the
1 litigation, who has been retained by a Party, or its counsel, to serve as an expert witness or as a
2 consultant in this Action.
3 2.8 House Counsel: attorneys who are the employees of a party to this Action and counsel
4 who are employees of the employing agency or department of a party. House Counsel does not
5 include Outside Counsel of Record or any other outside counsel.
6 2.9 Non-Party: any natural person, partnership, corporation, association, or other legal
7 entity not named as a Party to this Action.
8 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this
9 Action, but who are retained to represent or advise a party to this Action, and who have appeared
10 in this Action on behalf of that party, or who are affiliated with a law firm that has appeared on
11 behalf of that party; this includes support staff.
12 2.11 Party: any party to this Action, including all of the party’s officers, directors,
13 employees, consultants, retained experts, and Outside Counsel of Record (and their support
14 staffs).
15 2.12 Producing Party: a Party, or Non-Party, who produces Disclosure or Discovery
16 Material in this Action.
17 2.13 Professional Vendors: persons or entities providing litigation support services (e.g.,
18 photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing,
19 storing, or retrieving data in any form or medium) and their employees and subcontractors.
20 2.14 Protected Material: any Disclosure or Discovery Material designated as
21 “CONFIDENTIAL.”
22 2.15 Receiving Party: a Party who receives Disclosure or Discovery Material from a
23 Producing Party.
24 3. SCOPE
25 The protections this Stipulation and Order confer apply not only to Protected Material (as
26 defined above), but also to: (1) any information copied or extracted from Protected Material; (2)
27 all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
28 conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
1 This Order does not govern the use of Protected Material at trial; any use of Protected
2 Material at trial shall be governed by the orders of the trial judge.
3 4. DURATION
4 Even after final disposition of this litigation, the obligations of confidentiality this Order
5 imposes shall remain in effect until a Designating Party agrees otherwise in writing, or until a
6 court order directs otherwise. A final disposition shall be deemed as the later of: (1) dismissal of
7 all claims and defenses in this Action, with or without prejudice; and (2) final judgment herein
8 following the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
9 the Action, including time limits for filing any motions or applications for extension of time
10 pursuant to applicable law.
11 5. DESIGNATING PROTECTED MATERIAL
12 5.1 Exercise of Restraint and Care in Designating Material for Protection.
13 Each Party or Non-Party who designates information or items for protection under this
14 Order must take care to limit any such designation to specific material that qualifies under the
15 appropriate standards. The Designating Party must designate for protection only those parts of
16 material, documents, items, or oral or written communications that qualify so that other portions
17 of the material, documents items, or communications for which protection is not warranted are
18 not swept unjustifiably within the ambit of this Order.
19 Mass, indiscriminate, or routinized designations are prohibited. Designations that are
20 shown to be clearly unjustified or that have been made for an improper purpose (e.g., to
21 unnecessarily encumber the case development process or to impose unnecessary expenses and
22 burdens on other parties) may expose the Designating Party to sanctions.
23 If it comes to a Designating Party’s attention that information or items that it designated
24 for protection do not qualify for protection, that Designating Party must promptly notify all other
25 Parties that it is withdrawing the inapplicable designation.
26 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see,
27 e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
28 or Discovery Material that qualifies for protection under this Order must be clearly so designated
1 before the material is disclosed or produced.
2 Designation in conformity with this 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” (hereinafter “CONFIDENTIAL
6 legend”), to each page that contains protected material. If only a portion, or portions, of the
7 material on a page qualifies for protection, the Producing Party also must clearly identify the
8 protected portion(s) (e.g., by making appropriate 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 Order. Then,
15 before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL
16 legend” to each page that contains Protected Material. If only a portion, or portions, of the
17 material on a page qualifies for protection, the Producing Party also must clearly identify the
18 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 Disclosure,
20 or Discovery Material, on the record before the close of the deposition all protected testimony.
21 (c) for information produced in some form other than documentary, and for any other
22 tangible items, that the Producing Party affix in a prominent place on the exterior of the container,
23 or containers, in which the information is stored the “CONFIDENTIAL legend.” If only a portion
24 or portions of the information warrants protection, the Producing Party, to the extent practicable,
25 shall identify the protected portion(s).
26 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
27 designate qualified information or items does not, standing alone, waive the Designating Party’s
28 right to secure protection under this Order for such material. Upon timely correction of a
1 designation, the Receiving Party must make reasonable efforts to assure that the material is
2 treated in accordance with the provisions of this Order.
3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
5 confidentiality at any time that is consistent with the Court’s Scheduling Order.
6 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process
7 under Local Rules 141 and 141.1.
8 6.3 The burden of persuasion in any such challenge proceeding shall be on the
9 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass
10 or impose unnecessary expenses and burdens on other parties) may expose the Challenging Party
11 to sanctions. Unless the Designating Party has waived or withdrawn the confidentiality
12 designation, all parties shall continue to afford the material in question the level of protection to
13 which it is entitled under the Producing Party’s designation until the Court rules on the challenge.
14 7. ACCESS TO AND USE OF PROTECTED MATERIAL
15 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or
16 produced by another Party or by a Non-Party in connection with this Action only for prosecuting,
17 defending, or attempting to settle this Action. Such Protected Material may be disclosed only to
18 the categories of persons and under the conditions described in this Order. When the Action has
19 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL
20 DISPOSITION).
21 Protected Material must be stored and maintained by a Receiving Party at a location and
22 in a secure manner that ensures that access is limited to the persons authorized under this Order.
23 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by
24 the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
25 information or item designated “CONFIDENTIAL” only to:
26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as employees
27 of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information
28 for this Action;
1 (b) the officers, directors, and employees (including House Counsel) of the Receiving
2 Party to whom disclosure is reasonably necessary for this Action;
3 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
4 reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement
5 to Be Bound” (Exhibit A);
6 (d) the court and its personnel;
7 (e) court reporters and their staff;
8 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to whom
9 disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment
10 and Agreement to Be Bound” (Exhibit A);
11 (g) the author or recipient of a document containing the information or a custodian or
12 other person who otherwise possessed or knew the information;
13 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action to whom
14 disclosure is reasonably necessary provided: (1) the deposing party requests that the witness sign
15 the form attached as Exhibit A hereto; and (2) they will not be permitted to keep any confidential
16 information unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
17 unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed
18 deposition testimony or exhibits to depositions that reveal Protected Material may be separately
19 bound by the court reporter and may not be disclosed to anyone except as permitted under this
20 Stipulated Protective Order; and
21 (i) any mediator or settlement officer, and their supporting personnel, mutually agreed
22 upon by any of the parties engaged in settlement discussions.
23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
24 OTHER LITIGATION
25 If a Party is served with a subpoena or a court order issued in other litigation that compels
26 disclosure of any information or items designated in this Action as “CONFIDENTIAL,” that
27 Party must:
28 (a) promptly notify in writing the Designating Party. Such notification shall include a
1 copy of the subpoena or court order;
2 (b) promptly notify in writing the party who caused the subpoena or order to issue in the
3 other litigation that some or all of the material covered by the subpoena or order is subject to this
4 Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and
5 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
6 Designating Party whose Protected Material may be affected.
7 If the Designating Party timely seeks a protective order, the Party served with the
8 subpoena or court order shall not produce any information designated in this action as
9 “CONFIDENTIAL” before a determination by the court from which the subpoena or order
10 issued, unless the Party has obtained the Designating Party’s permission. The Designating Party
11 shall bear the burden and expense of seeking protection in that court of its confidential material
12 and nothing in these provisions should be construed as authorizing or encouraging a Receiving
13 Party in this Action to disobey a lawful directive from another court.
14 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
15 IN THIS LITIGATION
16 (a) The terms of this Order are applicable to information produced by a Non-Party in this
17 Action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in
18 connection with this litigation is protected by the remedies and relief provided by this Order.
19 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking
20 additional protections.
21 (b) In the event that a Party is required, by a valid discovery request, to produce a Non-
22 Party’s confidential information in its possession, and the Party is subject to an agreement with
23 the Non-Party not to produce the Non-Party’s confidential information, then the Party shall:
24 (1) promptly notify in writing the Requesting Party and the Non-Party that some or
25 all of the information requested is subject to a confidentiality agreement with a Non-Party;
26 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order
27 in this Action, the relevant discovery request(s), and a reasonably specific description of the
28 information requested; and
1 (3) make the information requested available for inspection by the Non-Party, if
2 requested.
3 (c) If the Non-Party fails to seek a protective order from this court within 14 days of
4 receiving the notice and accompanying information, the Receiving Party may produce the Non-
5 Party’s confidential information responsive to the discovery request. If the Non-Party timely
6 seeks a protective order, the Receiving Party shall not produce any information in its possession
7 or control that is subject to the confidentiality agreement with the Non-Party before a
8 determination by the court. Absent a court order to the contrary, the Non-Party shall bear the
9 burden and expense of seeking protection in this court of its Protected Material.
10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
12 Material to any person or, in any circumstance not authorized under this Stipulated Protective
13 Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the
14 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
15 Protected Material, (c) inform the person or persons to whom unauthorized disclosures were
16 made of all the terms of this Order, and (d) request such person or persons execute the
17 “Acknowledgment and Agreement to Be Bound” attached hereto as Exhibit A.
18 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
19 PROTECTED MATERIAL
20 When a Producing Party gives notice to Receiving Parties that certain inadvertently
21 produced material is subject to a claim of privilege or other protection, the obligations of the
22 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This
23 provision is not intended to modify whatever procedure may be established in an e-discovery
24 order that provides for production without prior privilege review. Pursuant to Federal Rule of
25 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a
26 communication or information covered by the attorney-client privilege or work product
27 protection, the parties may incorporate their agreement in the stipulated protective order
28 submitted to the court.
1 12. MISCELLANEOUS
2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek
3 its modification by the Court in the future.
4 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order,
5 no Party waives any right it otherwise would have to object to disclosing or producing any
6 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no
7 Party waives any right to object on any ground to use in evidence of any of the material covered
8 by this Protective Order.
9 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected Material
10 must comply with Civil Local Rule 141. Protected Material may only be filed under seal pursuant
11 to a court order authorizing the sealing of the specific Protected Material at issue. If a Party’s
12 request to file Protected Material under seal is denied by the court, then the Receiving Party may
13 file the information in the public record unless otherwise instructed by the court.
14 13. FINAL DISPOSITION
15 After the final disposition of this Action, as defined in Section 4 (DURATION), within 60
16 days of a written request by the Designating Party, each Receiving Party must return all Protected
17 Material to the Producing Party or must destroy such material. As used in this subdivision, “all
18 Protected Material” includes all copies, abstracts, compilations, summaries, and any other format
19 reproducing or capturing any of the Protected Material. Whether the Protected Material is
20 returned or destroyed, the Receiving Party must submit a written certification to the Producing
21 Party (and, if not the same person or entity, to the Designating Party) by the 60-day deadline that
22 (1) identifies (by category, where appropriate) all the Protected Material that was returned or
23 destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts,
24 compilations, summaries or any other format reproducing or capturing any of the Protected
25 Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
26 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
27 correspondence, deposition and trial exhibits, expert reports, attorney work product, and
28 consultant and expert work product, even if such materials contain Protected Material. Any such
1 archival copies that contain or constitute Protected Material remain subject to this Protective
2 Order as set forth in Section 4 (DURATION).
3 14. VIOLATION OF ORDER
4 Any violation of this Order may be punished by any and all appropriate measures
5 including, without limitation, contempt proceedings and/or monetary sanctions.
6
7 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

8
Dated: March 6, 2026 Respectfully submitted,
9
ROB BONTA
10 Attorney General of California
ELIZABETH S. ANGRES
11 Supervising Deputy Attorney General
EMILY WILLIAMS
12 Deputy Attorney General

13 /s/ Stephanie A. Vollmer
STEPHANIE A. VOLLMER
14 Deputy Attorney General
Attorneys for Defendant Jeremy Franchini
15
16 Dated: March 6, 2026 Respectfully Submitted,

17 POINTER & BUELNA, LLP
LAWYERS FOR THE PEOPLE
18
19 By: /s/ Michael A. Slater
(as authorized on 3/6/26)
20 ADANTE D. POINTER
PATRICK M. BUELNA
21 MICHAEL A. SLATER
Counsel for Plaintiffs
22 DAWN SEGROVES and CAMERON
HALL
23
24
25
26
27
28
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 of
5
perjury, that I have read in its entirety and understand the Stipulated Protective Order that was
6
issued by the United States District Court for the Eastern District of California on
7
____________[date] in the case of Dawn Segroves, individually; and Cameron Hall, individually
8
and as successor-in-interest to the Estate of Holly Segroves v. Jeremy Franchini, et al., United
9
States District Court for the Eastern District of California case number 2:25-cv-03076-WBS-
10
CSK. I agree to comply with and to be bound by all the terms of this Stipulated Protective Order,
11
and I understand and 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 not disclose in any manner
13
any information or item that is subject to this Stipulated Protective Order to any person or entity
14
except in strict compliance with the provisions of this Order.
15
I further agree to submit to the jurisdiction of the United States District Court for the
16
Eastern District of California for the purpose of enforcing the terms of this Stipulated Protective
17
Order, even if such enforcement proceedings occur after termination of this action. I hereby
18
appoint __________________________ [print or type full name] of
19
_______________________________________ [print or type full address and telephone
20
number] as my California agent for service of process in connection with this action or any
21
proceedings related to enforcement of this Stipulated Protective Order.
22

23
Date: _________________ ___________________________________
24
[Signature]
25
___________________________________
26
[City and State where sworn]
27
SA2025604783
28

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11377802. Public record. Not legal advice.