The opinion
mjk@kentpincinlaw.com
2 Emily R. Pincin, Esq. (SBN 334566)
erp@kentpincinlaw.com
3 KENT | PINCIN, LLP
120 Fisherman's Wharf
4 Redondo Beach, CA 90277
Tel: (310) 424-4991
5
6 Attorneys for Plaintiff
JOSHUA ABHAT
7
Mark S. Askanas (SBN 122745)
8 Regan M. Heslop (SBN 346293)
JACKSON LEWIS P.C.
9
50 California Street, Suite 900
10 San Francisco, CA 94111
Telephone: (415) 394-9400
11 Facsimile: (415) 394-9401
Email: mark.askanas@jacksonlewis.com
12 regan.heslop@jacksonlewis.com
13
Attorneys for Defendant
14 EDUCATIONAL CREDIT
MANAGEMENT CORPORATION
15
UNITED STATES DISTRICT COURT
16
EASTERN DISTRICT OF CALIFORNIA
17
18
19 JOSHUA ABHAT, an Individual, CASE NO.: 2:25-cv-01986-DAD-JDP
20
Plaintiff, STIPULATION FOR ENTRY OF
21 PROTECTIVE ORDER
v.
22
Filed: June 16, 2025
23 EDUCATIONAL CREDIT MANAGEMENT Answer: July 16, 2025
CORPORATION, a Minnesota Corporation Removed: July 16, 2025
24 DOES 1 through 100, inclusive, Trial: August 17, 2027
25
Defendants.
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2 (“Plaintiff”) and Defendant Educational Credit Management Corporation
3 (“Defendant”) (collectively, the “Parties”) in the above-entitled action, Joshua Abhat
4 v. Educational Credit Management Corporation (Case No. 2:25-cv-01986-DAD-
5 JDP), by and through their respective counsel of record, for the purpose of jointly
6 requesting that the honorable Court enter a protective order regarding documents
7 which may be subject to confidentiality limitations due to federal laws, state laws,
8 and privacy rights, the Parties stipulate and agree as follows:
9 1. PURPOSES AND LIMITATIONS
10 Disclosure and discovery activity in this action are likely to involve
11 production of confidential, proprietary, or private information for which special
12 protection from public disclosure and from use for any purpose other than
13 prosecuting this litigation would be warranted. Accordingly, the parties hereby
14 stipulate to and petition the court to enter the following Stipulation and Order. The
15 parties acknowledge that this Stipulation and Order does not confer blanket
16 protections on all disclosures or responses to discovery and that the protection it
17 affords extends only to the limited information or items that are entitled, under the
18 applicable legal principles, to treatment as confidential. The parties further
19 acknowledge, as set forth below, that this Stipulation and Order creates no
20 entitlement to file confidential information under seal; Eastern District Local Rule
21 141 sets forth the procedures that must be followed and reflects the standards that
22 will be applied when a party seeks permission from the court to file material under
23 seal.
24 Nothing in this Stipulation and Order shall be construed so as to require or
25 mandate that any Party disclose or produce privileged information or records that
26 could be designated as Confidential Documents/Protected Material hereunder.
27 / / /
28 / / /
2 This action is likely to involve confidential and/or sensitive medical
3 information, trade secrets, customer lists, and other valuable research, development,
4 commercial, financial, technical and/or proprietary information for which special
5 protection from public disclosure and from use for any purpose other than
6 prosecution of this action is warranted. Such confidential, sensitive, and/or
7 proprietary materials and information consist of, among other things, confidential
8 and/or sensitive medical information, confidential business or financial information,
9 information regarding confidential business practices, or other confidential research,
10 development, or commercial information (including information implicating privacy
11 rights of third parties), information otherwise generally unavailable to the public, or
12 which may be privileged or otherwise protected from disclosure under state or
13 federal statutes, court rules, case decisions, or common law. Accordingly, to
14 expedite the flow of information, to facilitate the prompt resolution of disputes over
15 confidentiality of discovery materials, to adequately protect information the parties
16 are entitled to keep confidential, to ensure that the parties are permitted reasonable
17 necessary uses of such material in preparation for and in the conduct of trial, to
18 address their handling at the end of the litigation, and serve the ends of justice, a
19 protective order for such information is justified in this matter. It is the intent of the
20 Parties that information will not be designated as confidential for tactical reasons and
21 that nothing be so designated without a good faith belief that it has been maintained
22 in a confidential, non-public manner, and there is good cause why it should not be
23 part of the public record of this case.
24 3. DEFINITIONS
25 3.1 Action: the lawsuit pending before this Court entitled Joshua Abhat v.
26 Educational Credit Management Corporation (Case No. 2:25-cv-01986-DAD-JDP).
27 3.2 Challenging Party: a Party or Non-Party that challenges the designation
28 of information or items under this Order.
2 how it is generated, stored or maintained) or tangible things that qualify for
3 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
4 the Good Cause Statement.
5 3.4 Counsel (without qualifier): Outside Counsel of Record and House
6 Counsel (as well as their support staff).
7 3.5 Designating Party: a Party or Non-Party that designates information or
8 items that it produces in disclosures or in responses to discovery as
9 “CONFIDENTIAL.”
10 3.6 Disclosure or Discovery Material: all items or information, regardless of
11 the medium or manner in which it is generated, stored, or maintained (including,
12 among other things, testimony, transcripts, and tangible things), that are produced or
13 generated in disclosures or responses to discovery in this matter.
14 3.7 Expert: a person with specialized knowledge or experience in a matter
15 pertinent to the litigation who has been retained by a Party or its counsel to serve as
16 an expert witness or as a consultant in this Action.
17 3.8 House Counsel: attorneys who are employees of a party to this Action.
18 House Counsel does not include Outside Counsel of Record or any other outside
19 counsel.
20 3.9 Non-Party: any natural person, partnership, corporation, association, or
21 other legal entity not named as a Party to this Action.
22 3.10 Outside Counsel of Record: attorneys who are not employees of a party
23 to this Action but are retained to represent or advise a party to this Action and have
24 appeared in this Action on behalf of that party or are affiliated with a law firm which
25 has appeared on behalf of that party.
26 3.11 Party: any party to this Action, including all of its officers, directors,
27 employees, consultants, retained experts, and Outside Counsel of Record (and their
28 support staffs).
2 Discovery Material in this Action.
3 3.13 Professional Vendors: persons or entities that provide litigation support
4 services (e.g., photocopying, videotaping, translating, preparing exhibits or
5 demonstrations, and organizing, storing, or retrieving data in any form or medium)
6 and their employees and subcontractors.
7 3.14 Protected Material: any Disclosure or Discovery Material that is
8 designated as “CONFIDENTIAL.”
9 3.15 Receiving Party: a Party that receives Disclosure or Discovery Material
10 from a Producing Party.
11 4. SCOPE
12 The protections conferred by this Stipulation and Order cover not only
13 Protected Material (as defined above), but also (1) any information copied or
14 extracted from Protected Material; (2) all copies, excerpts, summaries, or
15 compilations of Protected Material; and (3) any testimony, conversations, or
16 presentations by Parties or their Counsel that might reveal Protected Material.
17 However, the protections conferred by this Stipulation and Order do not cover
18 the following information: (a) any information that is in the public domain at the
19 time of disclosure to a Receiving Party or becomes part of the public domain after its
20 disclosure to a Receiving Party as a result of publication not involving a violation of
21 this Order, including becoming part of the public record through trial or otherwise;
22 and (b) any information known to the Receiving Party prior to the disclosure or
23 obtained by the Receiving Party after the disclosure from a source who obtained the
24 information lawfully and under no obligation of confidentiality to the Designating
25 Party. Any use of Protected Material at trial shall be governed by a separate
26 agreement or order.
27 ///
28 ///
2 Once a case proceeds to final disposition, information that was designated as
3 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
4 as an exhibit at trial becomes public and will be presumptively available to all
5 members of the public, including the press, unless compelling reasons supported by
6 specific factual findings to proceed otherwise are made to the trial judge in advance
7 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
8 showing for sealing documents produced in discovery from “compelling reasons”
9 standard when merits-related documents are part of court record). Final disposition
10 shall be deemed to be the later of (1) dismissal of all claims and defenses in this
11 Action, with or without prejudice; and (2) final judgment herein after the completion
12 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
13 including the time limits for filing any motions or applications for extension of time
14 pursuant to applicable law. Accordingly, the terms of this protective order do not
15 extend beyond the commencement of the trial.
16 6. DESIGNATING PROTECTED MATERIAL
17 6.1 Exercise of Restraint and Care in Designating Material for Protection.
18 Each Party or Non-Party that designates information or items for protection under
19 this Order must take care to limit any such designation to specific material that
20 qualifies under the appropriate standards. The Designating Party must designate for
21 protection only those parts of material, documents, items, or oral or written
22 communications that qualify – so that other portions of the material, documents,
23 items, or communications for which protection is not warranted are not swept
24 unjustifiably within the ambit of this Order.
25 Mass, indiscriminate, or routinized designations are prohibited. Designations
26 that are shown to be clearly unjustified or that have been made for an improper
27 purpose (e.g., to unnecessarily encumber or retard the case development process or
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2 Designating Party to sanctions.
3 If it comes to a Designating Party’s attention that information or items that it
4 designated for protection do not qualify for protection, that Designating Party must
5 promptly notify all other Parties that it is withdrawing the mistaken designation.
6 6.2 Manner and Timing of Designations. Except as otherwise provided in
7 this Order (see, e.g., second paragraph of section 6.2(a) below), or as otherwise
8 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
9 under this Order must be clearly so designated before the material is disclosed or
10 produced.
11 Designation in conformity with this Order requires:
12 (a) For information in documentary form (e.g., paper or electronic
13 documents, but excluding transcripts of depositions or other pretrial or trial
14 proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to each
15 page that contains protected material. If only a portion or portions of the material on
16 a page qualifies for protection, the Producing Party also must clearly identify the
17 protected portion(s) (e.g., by making appropriate markings in the margins).
18 A Party or Non-Party that makes original documents or materials available for
19 inspection need not designate them for protection until after the inspecting Party has
20 indicated which material it would like copied and produced. During the inspection
21 and before the designation, all of the material made available for inspection shall be
22 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
23 it wants copied and produced, the Producing Party must determine which documents,
24 or portions thereof, qualify for protection under this Order. Then, before producing
25 the specified documents, the Producing Party must affix the “CONFIDENTIAL”
26 legend to each page that contains Protected Material. If only a portion or portions of
27 the material on a page qualifies for protection, the Producing Party also must clearly
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2 margins).
3 (b) for testimony given in deposition or in other pretrial or trial
4 proceedings, that the Designating Party identify the Disclosure or Discovery Material
5 on the record, before the close of the deposition, hearing, or other proceeding, all
6 protected testimony.
7 (c) for information produced in some form other than documentary and for
8 any other tangible items, that the Producing Party affix in a prominent place on the
9 exterior of the container or containers in which the information or item is stored the
10 legend “CONFIDENTIAL.” If only a portion or portions of the information or item
11 warrant protection, the Producing Party, to the extent practicable, shall identify the
12 protected portion(s).
13 6.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
14 failure to designate qualified information or items does not, standing alone, waive
15 the Designating Party’s right to secure protection under this Order for such material.
16 Upon timely correction of a designation, the Receiving Party must make reasonable
17 efforts to assure that the material is treated in accordance with the provisions of this
18 Order.
19 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS
20 7.1 Timing of Challenges. Any Party or Non-Party may challenge a
21 designation of confidentiality at any time consistent with the Court’s Scheduling
22 Order. Unless a prompt challenge to a Designating Party’s confidentiality
23 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary
24 economic burdens, or a significant disruption or delay of the litigation, a Party does
25 not waive its right to challenge a confidentiality designation by electing not to mount
26 a challenge promptly after the original designation is disclosed.
27 / / /
28 / / /
2 resolution process by providing written notice of each designation it is challenging
3 and describing the basis for each challenge. To avoid ambiguity as to whether a
4 challenge has been made, the written notice must recite that the challenge to
5 confidentiality is being made in accordance with this specific paragraph of the
6 Protective Order. The parties shall attempt to resolve each challenge in good faith
7 and must begin the process by conferring directly (in voice to voice dialogue; other
8 forms of communication are not sufficient) within 14 days of the date of service of
9 notice. In conferring, the Challenging Party must explain the basis for its belief that
10 the confidentiality designation was not proper and must give the Designating Party
11 an opportunity to review the designated material, to reconsider the circumstances,
12 and, if no change in designation is offered, to explain the basis for the chosen
13 designation. A Challenging Party may proceed to the next stage of the challenge
14 process only if it has engaged in this meet and confer process first or establishes that
15 the Designating Party is unwilling to participate in the meet and confer process in a
16 timely manner.
17 7.3 Judicial Intervention. If the Parties cannot resolve a challenge without
18 court intervention, the Parties shall file a Joint Statement re Discovery Disagreement
19 pursuant to Civil Local Rule 251(c).
20 The burden of persuasion in any such challenge proceeding shall be on the
21 Designating Party. Frivolous challenges, and those made for an improper purpose
22 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
23 expose the Challenging Party to sanctions. All parties shall continue to afford the
24 material in question the level of protection to which it is entitled under the Producing
25 Party’s designation until the court rules on the challenge.
26 / / /
27 / / /
28 / / /
2 8.1 Basic Principles. A Receiving Party may use Protected Material that is
3 disclosed or produced by another Party or by a Non-Party in connection with this
4 case only for prosecuting, defending, or attempting to settle this litigation. Such
5 Protected Material may be disclosed only to the categories of persons and under the
6 conditions described in this Order. When the litigation has been terminated, a
7 Receiving Party must comply with the provisions of section 13 below (FINAL
8 DISPOSITION).
9 Protected Material must be stored and maintained by a Receiving Party at a
10 location and in a secure manner that ensures that access is limited to the persons
11 authorized under this Order.
12 8.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
13 ordered by the court or permitted in writing by the Designating Party, a Receiving
14 Party may disclose any information or item designated “CONFIDENTIAL” only to:
15 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
16 as employees of said Outside Counsel of Record to whom it is reasonably necessary
17 to disclose the information for this litigation;
18 (b) the officers, directors, and employees (including House Counsel) of the
19 Receiving Party to whom disclosure is reasonably necessary for this litigation;
20 (c) Experts (as defined in this Order) of the Receiving Party to whom
21 disclosure is reasonably necessary for this litigation and who have signed the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
23 (d) the court and its personnel;
24 (e) court reporters and their staff, professional jury or trial consultants,
25 mock jurors, and Professional Vendors to whom disclosure is reasonably necessary
26 for this litigation and who have signed the “Acknowledgment and Agreement to Be
27 Bound” (Exhibit A);
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2 reasonably necessary and who have signed the “Acknowledgment and Agreement to
3 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered
4 by the court. Pages of transcribed deposition testimony or exhibits to depositions that
5 reveal Protected Material must be separately bound by the court reporter and may not
6 be disclosed to anyone except as permitted under this Stipulated Protective Order;
7 (g) the author or recipient of a document containing the information or a
8 custodian or other person who otherwise possessed or knew the information;
9 (h) any mediators or settlement officers and their supporting personnel,
10 mutually agreed upon by any of the parties engaged in settlement discussions.
11 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
12 IN OTHER LITIGATION
13 If a Party is served with a subpoena or a court order issued in other litigation
14 that compels disclosure of any information or items designated in this Action as
15 “CONFIDENTIAL,” that Party must:
16 (a) promptly notify in writing the Designating Party. Such notification shall
17 include a copy of the subpoena or court order;
18 (b) promptly notify in writing the party who caused the subpoena or order
19 to issue in the other litigation that some or all of the material covered by the
20 subpoena or order is subject to this Protective Order. Such notification shall include
21 a copy of this Stipulated Protective Order; and
22 (c) cooperate with respect to all reasonable procedures sought to be pursued
23 by the Designating Party whose Protected Material may be affected.
24 If the Designating Party timely seeks a protective order, the Party served with
25 the subpoena or court order shall not produce any information designated in this
26 action as “CONFIDENTIAL” before a determination by the court from which the
27 subpoena or order issued, unless the Party has obtained the Designating Party’s
28 permission. The Designating Party shall bear the burden and expense of seeking
2 should be construed as authorizing or encouraging a Receiving Party in this action to
3 disobey a lawful directive from another court.
4 10. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
5 PRODUCED IN THIS LITIGATION
6 (a) The terms of this Order are applicable to information produced by a
7 Non-Party in this action and designated as “CONFIDENTIAL.” Such information
8 produced by Non-Parties in connection with this litigation is protected by the
9 remedies and relief provided by this Order. Nothing in these provisions should be
10 construed as prohibiting a Non-Party from seeking additional protections.
11 (b) In the event that a Party is required, by a valid discovery request, to
12 produce a Non-Party’s confidential information in its possession, and the Party is
13 subject to an agreement with the Non-Party not to produce the Non-Party’s
14 confidential information, then the Party shall:
15 (1) promptly notify in writing the Requesting Party and the Non-
16 Party that some or all of the information requested is subject to a confidentiality
17 agreement with a Non-Party;
18 (2) promptly provide the Non-Party with a copy of the Stipulated
19 Protective Order in this litigation, the relevant discovery request(s), and a reasonably
20 specific description of the information requested; and
21 (3) make the information requested available for inspection by the
22 Non-Party.
23 (c) If the Non-Party fails to object or seek a protective order from this court
24 within 14 days of receiving the notice and accompanying information, the Receiving
25 Party may produce the Non-Party’s confidential information responsive to the
26 discovery request. If the Non-Party timely seeks a protective order, the Receiving
27 Party shall not produce any information in its possession or control that is subject to
28 the confidentiality agreement with the Non-Party before a determination by the
2 expense of seeking protection in this court of its Protected Material.
3 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
5 Protected Material to any person or in any circumstance not authorized under this
6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
7 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
8 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
9 persons to whom unauthorized disclosures were made of all the terms of this Order,
10 and (d) request such person or persons to execute the “Acknowledgment and
11 Agreement to Be Bound” that is attached hereto as Exhibit A.
12 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
13 PROTECTED MATERIAL
14 When a Producing Party gives notice to Receiving Parties that certain
15 inadvertently produced material is subject to a claim of privilege or other protection,
16 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
17 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
18 may be established in an e-discovery order that provides for production without prior
19 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
20 parties reach an agreement on the effect of disclosure of a communication or
21 information covered by the attorney-client privilege or work product protection, the
22 parties may incorporate their agreement in the stipulated protective order submitted
23 to the court.
24 13. MISCELLANEOUS
25 13.1 Right to Further Relief. Nothing in this Order abridges the right of any
26 person to seek its modification by the court in the future.
27 / / /
28 / / /
2 Protective Order no Party waives any right it otherwise would have to object to
3 disclosing or producing any information or item on any ground not addressed in this
4 Stipulated Protective Order. Similarly, no Party waives any right to object on any
5 ground to use in evidence of any of the material covered by this Protective Order.
6 13.3 Filing Protected Material. Without written permission from the
7 Designating Party or a court order secured after appropriate notice to all interested
8 persons, a Party may not file in the public record in this action any Protected
9 Material. A Party that seeks to file under seal any Protected Material must comply
10 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
12 Receiving Party's request to file Protected Material under seal pursuant to Civil
13 Local Rule 141 is denied by the court, then the Receiving Party may file the
14 information in the public record pursuant to Civil Local Rule 141 unless otherwise
15 instructed by the court.
16 13. FINAL DISPOSITION
17 Within 60 days after the final disposition of this Action, as defined in
18 paragraph 5, each Receiving Party must return all Protected Material to the
19 Producing Party or destroy such material. As used in this subdivision, “all Protected
20 Material” includes all copies, abstracts, compilations, summaries, and any other
21 format reproducing or capturing any of the Protected Material. Whether the
22 Protected Material is returned or destroyed, the Receiving Party must submit a
23 written certification to the Producing Party (and, if not the same person or entity, to
24 the Designating Party) by the 60 day deadline that (1) identifies (by category, where
25 appropriate) all the Protected Material that was returned or destroyed and (2) affirms
26 that the Receiving Party has not retained any copies, abstracts, compilations,
27 summaries or any other format reproducing or capturing any of the Protected
28 Material. Notwithstanding this provision, Counsel are entitled to retain an archival
2 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
3 work product, and consultant and expert work product, even if such materials contain
4 Protected Material. Any such archival copies that contain or constitute Protected
5 Material remain subject to this Protective Order as set forth in Section 4
6 (DURATION).
7 14. VIOLATION
8 Any violation of this Order may be punished by appropriate measures
9 including, without limitation, contempt proceedings and/or monetary sanctions.
10 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
11
12 Dated: April 1, 2026 KENT | PINCIN, LLP
13
14 By: /s/ Emily R. Pincin
Michael J. Kent
15 Emily R. Pincin
Attorneys for Plaintiff
16 JOSHUA ABHAT
17
18 Dated: April 1, 2026 JACKSON LEWIS P.C.
19
20 By: /s/ Regan Heslop
Mark Askanas
21 Regan Heslop
Attorneys for Defendant
22 EDUCATIONAL CREDIT
MANAGEMENT CORPORATION
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1 PURSUANT TO STIPULATION, IT IS SO ORDERED
2
3 IT ISSO ORDERED.
4 ( | { Sy —
Dated: _ April 1, 2026 Q_————
5 JEREMY D. PETERSON
6 UNITED STATES MAGISTRATE JUDGE
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TPrepesed} Order
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 perjury
5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Eastern District of California
7 on ______________[date] in the case of Joshua Abhat v. Educational Credit
8 Management Corporation, Case No. 2:25-cv-01986-DAD-JDP. I agree to comply
9 with and to be bound by all the terms of this Stipulated Protective Order and I
10 understand and acknowledge that failure to so comply could expose me to sanctions
11 and punishment in the nature of contempt. I solemnly promise that I will not disclose
12 in any manner any information or item that is subject to this Stipulated Protective
13 Order to any person or entity except in strict compliance with the provisions of this
14 Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Eastern District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action.
19 I hereby appoint __________________________ [print or type full name] of
20 _______________________________________ [print or type full address and
21 telephone number] as my California agent for service of process in connection with
22 this action or any proceedings related to enforcement of this Stipulated Protective
23 Order.
24 Date: ______________________________________
25 City and State where sworn and signed: _________________________________
26 Printed name: _______________________________
27 Signature: __________________________________
28