The opinion
1 Lisa W. Lee (SBN 186495)
E-mail: llee@bwslaw.com
2 Marvin C. Cho (SBN 300941)
E-mail: mcho@bwslaw.com
3 BURKE, WILLIAMS & SORENSEN, LLP
444 South Flower Street, 40th Floor
4 Los Angeles, California 90071-2942
Tel: 213.236.0600 Fax: 213.236.2700
5
Attorneys for Defendants
6 CITY OF MONTEREY PARK and
MONTEREY PARK POLICE
7 DEPARTMENT
8
9
10 UNITED STATES DISTRICT COURT
11 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
12
13 JULIEN SELLS, an individual, and Case No. 2:26-CV-00702-FMO (CTSx)
JACE SELLS, a minor, by and through
14 his father JULIEN SELLS, Hon. Fernando M. Olguin
15 Plaintiffs, [PROPOSED] STIPULATED
PROTECTIVE ORDER1
16 v.
17 CITY OF MONTEREY PARK;
MONTEREY PARK POLICE
18 DEPARTMENT; and DOES 1-20,
inclusive,
19
Defendants.
20
21
22 1. GENERAL
23 1.1 Purposes and Limitations. Discovery in this action is likely to involve
24 production of confidential, proprietary, or private information for which special
25 protection from public disclosure and from use for any purpose other than
26
27 1 This Stipulated Protective Order is substantially based on the model protective
order provided under Magistrate Judge Alicia G. Rosenberg’s Procedures.
1 prosecuting this litigation may be warranted. Accordingly, the parties hereby
2 stipulate to and petition the Court to enter the following Stipulated Protective Order.
3 The parties acknowledge that this Order does not confer blanket protections on all
4 disclosures or responses to discovery and that the protection it affords from public
5 disclosure and use extends only to the limited information or items that are entitled
6 to confidential treatment under the applicable legal principles. The parties further
7 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective
8 Order does not entitle them to file confidential information under seal; Civil Local
9 Rule 79-5 sets forth the procedures that must be followed and the standards that will
10 be applied when a party seeks permission from the court to file material under seal.
11 1.2 Good Cause Statement. This action involves Plaintiffs JULIEN
12 SELLS and JACE SELLS (“Plaintiffs”) and Defendants CITY OF MONTEREY
13 PARK and MONTEREY PARK POLICE DEPARTMENT2 (collectively, the “City”
14 or “Defendants”). Plaintiff is seeking materials and information the City maintains as
15 confidential, such as officer body worn video recordings, audio recordings and
16 materials, and other administrative and personnel records which, if they exist, are in
17 the possession of the City which Defendants believe need special protection from
18 public disclosure and from use for any purpose other than prosecuting this litigation.
19 In addition, some materials sought pertain to a confidential criminal investigation,
20 which has not yet concluded, and disclosure of which could jeopardize the ongoing
21 investigation. See Shelley v. Cnty. of San Joaquin, 2015 WL 2082370, at *3 (E.D.
22 Cal. May 4, 2015); United States v. Smith, 985 F.Supp.2d 506, 531 (S.D.N.Y.2013);
23 Flagg ex rel. Bond v. City of Detroit, 268 F.R.D. 279, 294 (E.D.Mich.2010); Tuite v.
24 Henry, 181 F.R.D. 175, 179 (D.D.C.1998). See generally Center for Nat. Sec. Studies
25 v. U.S. Dept. of Justice, 331 F.3d 918, 926 (D.C.Cir.2003); United States v. Valenti,
26
27 2 The MONTEREY PARK POLICE DEPARTMENT is not a separate legal entity,
but instead a department within the City of Monterey Park.
1 987 F.2d 708, 714 (11th Cir.1993); Coughlin v. Lee, 946 F.2d 1152, 1159 (5th
2 Cir.1991); Swanner v. United States, 406 F.2d 716, 719 (5th Cir. 1969). As it pertains
3 to these materials, they will be designated as “Attorney’s Eyes Only,” and shall only
4 be viewed by the attorney and treated in accordance with the terms of this Order.
5 Defendants assert that the confidentiality of the materials and information
6 sought by Plaintiffs is recognized by California and federal law, as evidenced inter
7 alia by California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for
8 N.D. Cal., 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The City
9 has not publicly released the materials and information referenced above. These
10 materials and information are of the type that have been used to initiate disciplinary
11 action against Monterey Park Police Department (“MPPD”) officers and have been
12 used as evidence in disciplinary proceedings where the officers’ conduct was
13 considered to be contrary to MPPD policy.
14 Defendants contend that absent a protective order delineating the
15 responsibilities of nondisclosure on the part of the parties hereto, there is a specific
16 risk of unnecessary and undue disclosure by one or more of the many attorneys,
17 secretaries, law clerks, paralegals and expert witnesses involved in this case, as well
18 as the corollary risk of embarrassment, harassment as well as professional, physical
19 and legal harm on the part of the MPPD officers referenced in the materials and
20 information.
21 Defendants also contend that the unfettered disclosure of the materials and
22 information, absent a protective order, would allow the media to share this
23 information with potential jurors in the area, impacting the rights of the Defendants
24 herein to receive a fair trial.
25 Accordingly, to expedite the flow of information, to facilitate the prompt
26 resolution of disputes over confidentiality of discovery materials, to adequately
27 protect information the parties are entitled to keep confidential, to ensure that the
1 in the conduct of trial, to address their handling at the end of the litigation, and serve
2 the ends of justice, a protective order for such information is justified in this matter.
3 It is the intent of the parties that information will not be designated as confidential for
4 tactical reasons and that nothing be so designated without a good faith belief that it
5 has been maintained in a confidential, non-public manner, and there is good cause
6 why it should not be part of the public record of this case. This also includes (1) any
7 information copied or extracted from the Confidential information; (2) copies,
8 excerpts, summaries or compilations of Confidential information; and (3) any
9 testimony, conversations, or presentations that might reveal Confidential information.
10
11 2. DEFINITIONS
12 2.1 Action: Julien Sells, et al. v. City of Monterey Park, et al., United
13 States District Court Case No. 2:26-CV-00702-FMO (AGRx).
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 (regardless of
17 how it is generated, stored or maintained) or tangible things that qualify for
18 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
19 the Good Cause Statement. This also includes (1) any information copied or
20 extracted from the Confidential information; (2) copies, excerpts, summaries or
21 compilations of Confidential information; and (3) any testimony, conversations, or
22 presentations that might reveal Confidential information.
23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
24 their support staff).
25 2.5 Designating Party: a Party or Non-Party that designates information or
26 items that it produces in disclosures or in responses to discovery as
27 “CONFIDENTIAL.”
1 of the medium or manner in which it is generated, stored, or maintained (including,
2 among other things, testimony, transcripts, and tangible things), that are produced or
3 generated in disclosures or responses to discovery in this matter.
4 2.7 Expert: a person with specialized knowledge or experience in a matter
5 pertinent to the litigation who has been retained by a Party or its counsel to serve as
6 an expert witness or as a consultant in this Action.
7 2.8 House Counsel: attorneys who are employees of a party to this Action.
8 House Counsel does not include Outside Counsel of Record or any other outside
9 counsel.
10 2.9 Non-Party: any natural person, partnership, corporation, association, or
11 other legal entity not named as a Party to this action.
12 2.10 Outside Counsel of Record: attorneys who are not employees of a
13 party to this Action but are retained to represent or advise a party to this Action and
14 have appeared in this Action on behalf of that party or are affiliated with a law firm
15 that has appeared on behalf of that party, including support staff.
16 2.11 Party: any party to this Action, including all of its officers, directors,
17 employees, consultants, retained experts, and Outside Counsel of Record (and their
18 support staffs).
19 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
20 Discovery Material in this Action.
21 2.13 Professional Vendors: persons or entities that provide litigation
22 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
23 demonstrations, and organizing, storing, or retrieving data in any form or medium)
24 and their employees and subcontractors.
25 2.14 Protected Material: any Disclosure or Discovery Material that is
26 designated as “CONFIDENTIAL.”
27 2.15 Receiving Party: a Party that receives Disclosure or Discovery
1 3. SCOPE
2 The protections conferred by this Stipulation and Order cover not only
3 Protected Material (as defined above), but also (1) any information copied or
4 extracted from Protected Material; (2) all copies, excerpts, summaries, or
5 compilations of Protected Material; and (3) any testimony, conversations, or
6 presentations by Parties or their Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the trial
8 judge. This Order does not govern the use of Protected Material at trial.
9
10 4. DURATION
11 Once a case proceeds to trial, all of the court-filed information to be
12 introduced that was previously designated as confidential or maintained pursuant to
13 this protective order becomes public and will be presumptively available to all
14 members of the public, including the press, unless compelling reasons supported by
15 specific factual findings to proceed otherwise are made to the trial judge in advance
16 of the trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81
17 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents
18 produced in discovery from “compelling reasons” standard when merits-related
19 documents are part of court record). Accordingly, the terms of this protective order
20 do not extend beyond the commencement of the trial.
21
22 5. DESIGNATING PROTECTED MATERIAL
23 5.1 Exercise of Restraint and Care in Designating Material for Protection.
24 Each Party or Non-Party that designates information or items for protection under
25 this Order must take care to limit any such designation to specific material that
26 qualifies under the appropriate standards. The Designating Party must designate for
27 protection only those parts of material, documents, items, or oral or written
1 items, or communications for which protection is not warranted are not swept
2 unjustifiably within the ambit of this Order.
3 Mass, indiscriminate, or routinized designations are prohibited. Designations that
4 are shown to be clearly unjustified or that have been made for an improper purpose
5 (e.g., to unnecessarily encumber the case development process or to impose
6 unnecessary expenses and burdens on other parties) may expose the Designating
7 Party to sanctions.
8 If it comes to a Designating Party’s attention that information or items that it
9 designated for protection do not qualify for protection, that Designating Party must
10 promptly notify all other Parties that it is withdrawing the inapplicable designation.
11 5.2 Manner and Timing of Designations. Except as otherwise provided in
12 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
13 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
14 under this Order must be clearly so designated before the material is disclosed or
15 produced.
16 Designation in conformity with this Order requires:
17 (a) for information in documentary form (e.g., paper or electronic
18 documents, but excluding transcripts of depositions or other pretrial or trial
19 proceedings), that the Producing Party affix, at a minimum, the legend
20 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
21 contains protected material. If only a portion or portions of the material on a page
22 qualifies for protection, the Producing Party also must clearly identify the protected
23 portion(s) (e.g., by making appropriate markings in the margins).
24 A Party or Non-Party that makes original documents available for inspection
25 need not designate them for protection until after the inspecting Party has indicated
26 which documents it would like copied and produced. During the inspection and
27 before the designation, all of the material made available for inspection shall be
1 documents it wants copied and produced, the Producing Party must determine which
2 documents, or portions thereof, qualify for protection under this Order. Then,
3 before producing the specified documents, the Producing Party must affix the
4 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
5 portion or portions of the material on a page qualifies for protection, the Producing
6 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
7 markings in the margins).
8 (b) for testimony given in depositions that the Designating Party
9 identify the Disclosure or Discovery Material on the record, before the close of the
10 deposition.
11 (c) for information produced in some form other than documentary and
12 for any other tangible items, that the Producing Party affix in a prominent place on
13 the exterior of the container or containers in which the information is stored the
14 legend “CONFIDENTIAL.” If only a portion or portions of the information
15 warrants protection, the Producing Party, to the extent practicable, shall identify the
16 protected portion(s).
17 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
18 failure to designate qualified information or items does not, standing alone, waive
19 the Designating Party’s right to secure protection under this Order for such material.
20 Upon timely correction of a designation, the Receiving Party must make reasonable
21 efforts to assure that the material is treated in accordance with the provisions of this
22 Order.
23
24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
26 designation of confidentiality at any time that is consistent with the Court’s
27 Scheduling Order.
1 resolution process under Local Rule 37-1, et seq. Any discovery motion must
2 strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
3 6.3 Burden. The burden of persuasion in any such challenge proceeding
4 shall be on the Designating Party. Frivolous challenges, and those made for an
5 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
6 other parties) may expose the Challenging Party to sanctions. Unless the
7 Designating Party has waived or withdrawn the confidentiality designation, all
8 parties shall continue to afford the material in question the level of protection to
9 which it is entitled under the Producing Party’s designation until the Court rules on
10 the challenge.
11
12 7. ACCESS TO AND USE OF PROTECTED MATERIAL
13 7.1 Basic Principles. A Receiving Party may use Protected Material that is
14 disclosed or produced by another Party or by a Non-Party in connection with this
15 Action only for prosecuting, defending, or attempting to settle this Action. Such
16 Protected Material may be disclosed only to the categories of persons and under the
17 conditions described in this Order. When the Action has been terminated, a
18 Receiving Party must comply with the provisions of section 13 below (FINAL
19 DISPOSITION).
20 Protected Material must be stored and maintained by a Receiving Party at a
21 location and in a secure manner that ensures that access is limited to the persons
22 authorized under this Order.
23 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
24 otherwise ordered by the Court or permitted in writing by the Designating Party, a
25 Receiving Party may disclose any information or item designated
26 “CONFIDENTIAL” only to:
27 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
1 necessary to disclose the information for this Action;
2 (b) the officers, directors, and employees (including House Counsel) of
3 the Receiving Party to whom disclosure is reasonably necessary for this Action;
4 (c) Experts (as defined in this Order) of the Receiving Party to whom
5 disclosure is reasonably necessary for this Action and who have signed the
6 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
7 (d) the Court and its personnel;
8 (e) court reporters and their staff;
9 (f) professional jury or trial consultants, mock jurors, and Professional
10 Vendors to whom disclosure is reasonably necessary for this Action and who have
11 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
12 (g) the author or recipient of a document containing the information or
13 a custodian or other person who otherwise possessed or knew the information;
14 (h) during their depositions, witnesses, and attorneys for witnesses, in
15 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
16 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
17 they will not be permitted to keep any confidential information unless they sign the
18 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
19 agreed by the Designating Party or ordered by the Court. Pages of transcribed
20 deposition testimony or exhibits to depositions that reveal Protected Material may
21 be separately bound by the court reporter and may not be disclosed to anyone except
22 as permitted under this Stipulated Protective Order; and
23 (i) any mediator or settlement officer, and their supporting personnel,
24 mutually agreed upon by any of the parties engaged in settlement discussions.
25
26 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
27 PRODUCED IN OTHER LITIGATION
1 that compels disclosure of any information or items designated in this Action as
2 “CONFIDENTIAL,” that Party must:
3 (a) promptly notify in writing the Designating Party. Such notification shall
4 include a copy of the subpoena or court order;
5 (b) promptly notify in writing the party who caused the subpoena or order to
6 issue in the other litigation that some or all of the material covered by the subpoena
7 or order is subject to this Protective Order. Such notification shall include a copy of
8 this Stipulated Protective Order; and
9 (c) cooperate with respect to all reasonable procedures sought to be pursued
10 by the Designating Party whose Protected Material may be affected.
11 If the Designating Party timely seeks a protective order, the Party served with the
12 subpoena or court order shall not produce any information designated in this action
13 as “CONFIDENTIAL” before a determination by the court from which the
14 subpoena or order issued, unless the Party has obtained the Designating Party’s
15 permission. The Designating Party shall bear the burden and expense of seeking
16 protection in that court of its confidential material and nothing in these provisions
17 should be construed as authorizing or encouraging a Receiving Party in this Action
18 to disobey a lawful directive from another court.
19
20 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
21 PRODUCED IN THIS LITIGATION
22 (a) The terms of this Order are applicable to information produced by a Non-
23 Party in this Action and designated as “CONFIDENTIAL.” Such information
24 produced by Non-Parties in connection with this litigation is protected by the
25 remedies and relief provided by this Order. Nothing in these provisions should be
26 construed as prohibiting a Non-Party from seeking additional protections.
27 (b) In the event that a Party is required, by a valid discovery request, to
1 subject to an agreement with the Non-Party not to produce the Non-Party’s
2 confidential information, then the Party shall:
3 (1) promptly notify in writing the Requesting Party and the Non-Party
4 that some or all of the information requested is subject to a confidentiality
5 agreement with a Non-Party;
6 (2) promptly provide the Non-Party with a copy of the Stipulated
7 Protective Order in this Action, the relevant discovery request(s), and a reasonably
8 specific description of the information requested; and
9 (3) make the information requested available for inspection by the
10 Non-Party, if requested.
11 (c) If the Non-Party fails to seek a protective order from this Court within 14
12 days of receiving the notice and accompanying information, the Receiving Party
13 may produce the Non-Party’s confidential information responsive to the discovery
14 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
15 not produce any information in its possession or control that is subject to the
16 confidentiality agreement with the Non-Party before a determination by the Court.
17 Absent a court order to the contrary, the Non-Party shall bear the burden and
18 expense of seeking protection in this Court of its Protected Material.
19
20 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
21 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
22 Protected Material to any person or in any circumstance not authorized under this
23 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
24 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
25 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
26 persons to whom unauthorized disclosures were made of all the terms of this Order,
27 and (d) request such person or persons to execute the “Acknowledgment and
1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
2 PROTECTED MATERIAL
3 When a Producing Party gives notice to Receiving Parties that certain
4 inadvertently produced material is subject to a claim of privilege or other protection,
5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
7 procedure may be established in an e-discovery order that provides for production
8 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
9 (e), insofar as the parties reach an agreement on the effect of disclosure of a
10 communication or information covered by the attorney-client privilege or work
11 product protection, the parties may incorporate their agreement in the stipulated
12 protective order submitted to the Court.
13
14 12. MISCELLANEOUS
15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
16 person to seek its modification by the Court in the future.
17 12.2 Right to Assert Other Objections. By stipulating to the entry of this
18 Protective Order, no Party waives any right it otherwise would have to object to
19 disclosing or producing any information or item on any ground not addressed in this
20 Stipulated Protective Order. Similarly, no Party waives any right to object on any
21 ground to use in evidence of any of the material covered by this Protective Order.
22 12.3 Filing Protected Material. A Party that seeks to file under seal any
23 Protected Material must comply with Civil Local Rule 79-5. Protected Material
24 may only be filed under seal pursuant to a court order authorizing the sealing of the
25 specific Protected Material at issue; good cause must be shown in the request to file
26 under seal. If a Party’s request to file Protected Material under seal is denied by the
27 Court, then the Receiving Party may file the information in the public record unless
1 13. FINAL DISPOSITION
2 After the final disposition of this Action, within 60 days of a written request by the
3 Designating Party, each Receiving Party must return all Protected Material to the
4 Producing Party or destroy such material. As used in this subdivision, “all Protected
5 Material” includes all copies, abstracts, compilations, summaries, and any other
6 format reproducing or capturing any of the Protected Material. Whether the
7 Protected Material is returned or destroyed, the Receiving Party must submit a
8 written certification to the Producing Party (and, if not the same person or entity, to
9 the Designating Party) by the 60 day deadline that (1) identifies (by category, where
10 appropriate) all the Protected Material that was returned or destroyed, and (2)
11 affirms that the Receiving Party has not retained any copies, abstracts, compilations,
12 summaries or any other format reproducing or capturing any of the Protected
13 Material. Notwithstanding this provision, counsel are entitled to retain an archival
14 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
15 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
16 work product, and consultant and expert work product, even if such materials
17 contain Protected Material. Any such archival copies that contain or constitute
18 Protected Material remain subject to this Protective Order as set forth in Section 4
19 (DURATION).
20
21 14. VIOLATION OF ORDER
22 Any violation of this Order may be punished by any and all appropriate
23 measures including, without limitation, contempt proceedings and/or monetary
24 sanctions.
25 ///
26 ///
27 ///
1 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2
3 || Dated: June 5, 2026 JOHNSON TRIAL LAW, LLC
4
5
6 By: /s/ James M. Johnson
James M. Johnson
7 Attorneys for Plaintiffs
8 JULIEN SELLS and JACE SELLS
9
10
Dated: June 5, 2026 BURKE, WILLIAMS & SORENSEN, LLP
12
13 By:
y: /s/ Lisa W. Lee
14 Lisa W. Lee
15 Marvin C. Cho
Attorneys for Defendants
16 CITY OF MONTEREY PARK and
7 MONTEREY PARK POLICE
DEPARTMENT
18
19
20
1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
22
June 11, 2026 Lo oo
3 DATED: (ie DK
HON. CHRISTINA T. SHAY
24 United States Magistrate Judge
25
26
27
28
E, WILLIAMS &
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [full name], of _________________ [full
5 address], declare under penalty of perjury that I have read in its entirety and
6 understand the Stipulated Protective Order that was issued by the United States
7 District Court for the Central District of California on ____________ [date] in the
8 case of Julien Sells, et al. v. City of Monterey Park, et al., United States District
9 Court Case No. 2:26-CV-00702-FMO (AGRx). I agree to comply with and to be
10 bound by all the terms of this Stipulated Protective Order and I understand and
11 acknowledge that failure to so comply could expose me to sanctions and punishment
12 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
14 person or entity 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 Central 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. I hereby appoint __________________________ [full
19 name] of _______________________________________ [full address and
20 telephone number] as my California agent for service of process in connection with
21 this action or any proceedings related to enforcement of this Stipulated Protective
22 Order.
23 Date: ______________________________________
24 City and State where signed: _________________________________
25
26 Printed name: _______________________________
27