The opinion
1
UNITED STATES DISTRICT COURT
2
3
CENTRAL DISTRICT OF CALIFORNIA
4
LISA RAUHAUSER,
5
6 Plaintiff(s), Case No. 2:25-CV-06048-J FW-DMK
7 Vv.
8 BEACON HILL SOLUTIONS STIPULATED PROTECTIVE
9 GROUP, LLC ORDER!
Defendant(s).
10
11
12
13 || 1. INTRODUCTION
14 1.1 Purposes and Limitations. Discovery in this action is likely to
15 || involve production of confidential, proprietary, or private information for
16 || which special protection from public disclosure and from use for any
17 || purpose other than prosecuting this litigation may be warranted.
18 || Accordingly, the parties hereby stipulate to and petition the court to
19 || enter the following Stipulated Protective Order. The parties
20 || acknowledge that this Order does not confer blanket protections on all
21 || disclosures or responses to discovery and that the protection it affords
22 || from public disclosure and use extends only to the limited information or
?3 || items that are entitled to confidential treatment under the applicable
24 □
legal principles.
25
———_ crc
97 || | This Stipulated Protective Order is substantially based on the model
protective order provided under Magistrate Judge Diana M. Kwok’s
28 || Procedures as of March 30, 2026.
1 || Good Cause Statement. This action is likely to involve trade secrets,
2 || customer and pricing lists and other valuable commercial, financial,
3 || technical and/or proprietary information for which special protection
4 || from public disclosure and from use for any purpose other than
5 || prosecution of this action is warranted. Such confidential and
6 || proprietary materials and information consist of, among other things,
7 periodic reports showing the number of placements made by Beacon
8 || Hill’s Legal Division personnel, frequency of contacts, profit margins,
|| customer names and volumes and profitability of placements, including
emails that are labeled “Weekly Reports” and year-end summaries of the
business results of Legal Division offices. In addition, there will be
2 confidential personal information about Beacon Hill employees which, if
not protected, would invade their privacy; such as home addresses and
telephone numbers, social security numbers, compensation information,
6 and information about their dependents. Accordingly, to expedite the
flow of information, to facilitate the prompt resolution of disputes over
8 confidentiality of discovery materials, to adequately protect information
19 the parties are entitled to keep confidential, to ensure that the parties
99 || are permitted reasonable necessary uses of such material in preparation
21 || for and in the conduct of trial, to address their handling at the end of the
22 || litigation, and serve the ends of justice, a protective order for such
23 || information is justified in this matter. It is the intent of the parties that
24 || information will not be designated as confidential for tactical reasons
25 || and that nothing be so designated without a good faith belief that it has
26 || been maintained in a confidential, non-public manner, and there is good
27 || cause why it should not be part of the public record of this case.
28
1 1.2 Acknowledgment of Procedure for Filing Under Seal. The
2 || parties further acknowledge, as set forth in Section 12.3, below, that this
3 || Stipulated Protective Order does not entitle them to file confidential
4 || information under seal; Local Rule 79-5 sets forth the procedures that
5 || must be followed and the standards that will be applied when a party
6 || seeks permission from the court to file material under seal.
7 There is a strong presumption that the public has a right of access
8 || to judicial proceedings and records in civil cases. In connection with
non-dispositive motions, good cause must be shown to support a filing
under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d
1172,.1176 (9th Cir,2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors
Corp., 307 F.3d 1206, 1210-11 (9th Cir,2002), Makar-Welbon v. Sony
Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
protective orders require good cause showing), and a specific showing of
6 good cause or compelling reasons with proper evidentiary support and
legal justification, must be made with respect to Protected Material that
is || 2 party seeks to file under seal. The parties’ mere designation of
19 || Disclosure or Discovery Material as CONFIDENTIAL does not—
29 || without the submission of competent evidence by declaration,
21 || establishing that the material sought to be filed under seal qualifies as
22 || confidential, privileged, or otherwise protectable—constitute good cause.
23 Further, if a party requests sealing related to a dispositive motion
24 || or trial, then compelling reasons, not only good cause, for the sealing
25 || must be shown, and the relief sought shall be narrowly tailored to serve
26 || the specific interest to be protected. See Pintos v. Pac. Creditors □□□□□□
27 || 605 F.3d 665, 677—79 (9th Cir. 2010). For each item or type of
28 || information, document, or thing sought to be filed or introduced under
1 || seal in connection with a dispositive motion or trial, the party seeking
2 || protection must articulate compelling reasons, supported by specific
3 || facts and legal justification, for the requested sealing order. Again,
4 || competent evidence supporting the application to file documents under
5 || seal must be provided by declaration.
6 Any document that is not confidential, privileged, or otherwise
7 protectable in its entirety will not be filed under seal if the confidential
8 portions can be redacted. If documents can be redacted, then a redacted
|! version for public viewing, omitting only the confidential, privileged, or
otherwise protectable portions of the document, shall be filed. Any
application that seeks to file documents under seal in their entirety
should include an explanation of why redaction is not feasible.
14
Is 2. DEFINITIONS
16 2.1 Action: this pending federal lawsuit.
7 2.2 Challenging Party: a Party or Non-Party that challenges the
ig || designation of information or items under this Order,
19 2.3 “CONFIDENTIAL” Information or Items: information
20 || (regardless of how it is generated, stored or maintained) or tangible
21 || things that qualify for protection under Rule 26(c) of the Federal Rules of
22 || Civil Procedure, and as specified above in the Good Cause Statement.
23 2.4 Counsel: Outside Counsel of Record and House Counsel (as
24 || well as their support staff).
25 2.5 Designating Party: a Party or Non-Party that designates
26 |! information or items that it produces in disclosures or in responses to
27 || discovery as “CONFIDENTIAL.”
28
1 2.6 Disclosure or Discovery Material: all items or information,
2 || regardless of the medium or manner in which it is generated, stored, or
3 || maintained (including, among other things, testimony, transcripts, and
4 || tangible things), that are produced or generated in disclosures or
5 || responses to discovery in this matter.
6 2.7 Expert: a person with specialized knowledge or experience in
7 | a matter pertinent to the litigation who has been retained by a Party or
8 || its counsel to serve as an expert witness or as a consultant in this Action.
2.8 Final Disposition: the later of (1) dismissal of all claims and
defenses in this Action, with or without prejudice; and (2) final judgment
herein after the completion and exhaustion of all appeals, rehearings,
remands, trials, or reviews of this Action, including the time limits for
filing any motions or applications for extension of time pursuant to
applicable law.
6 2.9 In-House Counsel: attorneys who are employees of a party to
this Action. In-House Counsel does not include Outside Counsel of
8 Record or any other outside counsel.
19 2.10 Non-Party: any natural person, partnership, corporation,
29 |} association, or other legal entity not named as a Party to this action.
1 2.11 Outside Counsel of Record: attorneys who are not employees
22 || of a party to this Action but are retained to represent or advise a party to
23 || this Action and have appeared in this Action on behalf of that party or
24 || are affiliated with a law firm which has appeared on behalf of that party,
25 || and includes support staff.
26 2.12 Party: any party to this Action, including all of its officers,
27 || directors, employees, consultants, retained experts, and Outside Counsel
28 || of Record (and their support staffs).
1 2.13 Producing Party: a Party or Non-Party that produces
2 || Disclosure or Discovery Material in this Action.
3 2.14 Professional Vendors: persons or entities that provide
4 || litigation- support services (e.g., photocopying, videotaping, translating,
5 || preparing exhibits or demonstrations, and organizing, storing, or
6 || retrieving data in any form or medium) and their employees and
7 || subcontractors.
8 2.15 Protected Material: any Disclosure or Discovery Material that
ll is designated as “CONFIDENTIAL.”
2.16 Receiving Party: a Party that receives Disclosure or Discovery
Material from a Producing Party.
13
4 3. SCOPE
15 The protections conferred by this Stipulation and Order cover not
16 || Only Protected Material (as defined above), but also (1) any information
i7 || copied or extracted from Protected Material; (2) all copies, excerpts,
ig || summaries, or compilations of Protected Material; and (3) any
19 || testimony, conversations, or presentations by Parties or their Counsel
20 || that might reveal Protected Material.
21 Any use of Protected Material at trial shall be governed by the
22 || orders of the trial judge. This Stipulated Protective Order does not
23 || govern the use of Protected Material at trial.
24
23 || 4. TRIAL AND DURATION
The terms of this Stipulated Protective Order apply through Final
Disposition of the Action.
1 Once a case proceeds to trial, information that was designated as
2 || CONFIDENTIAL or maintained pursuant to this Stipulated Protective
3 || Order and used or introduced as an exhibit at trial becomes public and
4 || will be presumptively available to all members of the public, including
5 || the press, unless compelling reasons supported by specific factual
6 || findings to proceed otherwise are made to the trial judge in advance of
7 || the trial. See Kamakana, 447 F.3d at 1180—81 (distinguishing “good
|! cause” showing for sealing documents produced in discovery from
“compelling reasons” standard when merits-related documents are part
10 of court record). Accordingly, for such materials, the terms of this
Stipulated Protective Order do not extend beyond the commencement of
the trial.
Even after Final Disposition of this litigation, the confidentiality
obligations imposed by this Stipulated Protective Order shall remain in
6 effect until a Designating Party agrees otherwise in writing or a court
order otherwise directs.
18
io || 5: DESIGNATING PROTECTED MATERIAL
20 5.1 Exercise of Restraint and Care in Designating Material for
21 || Protection. Each Party or Non-Party that designates information or
22 || items for protection under this Order must take care to limit any such
23 || designation to specific material that qualifies under the appropriate
24 || standards. The Designating Party must designate for protection only
29 || those parts of material, documents, items, or oral or written
26 | communications that qualify so that other portions of the material,
27 documents, items, or communications for which protection is not
28
1 || warranted are not swept unjustifiably within the ambit of this Order.
2 Mass, indiscriminate, or routinized designations are prohibited.
3 || Designations that are shown to be clearly unjustified or that have been
4 || made for an improper purpose (e.g., to unnecessarily encumber the case
5 || development process or to impose unnecessary expenses and burdens on
6 || other parties) may expose the Designating Party to sanctions.
7 If it comes to a Designating Party’s attention that information or
8 || items that it designated for protection do not qualify for protection, that
Designating Party must promptly notify all other Parties that it is
withdrawing the inapplicable designation.
5.2 Manner and Timing of Designations. Except as otherwise
3 provided in this Stipulated Protective Order (see, e.g., second paragraph
14 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
|| OF Discovery Material that qualifies for protection under this Stipulated
16 || Protective Order must be clearly so designated before the material is
17 || disclosed or produced.
18 Designation in conformity with this Stipulated Protective Order
19 || requires:
20 (a) for information in documentary form (e.g., paper or electronic
21 || documents, but excluding transcripts of depositions or other pretrial or
22 || trial proceedings), that the Producing Party affix at a minimum, the
23 || legend “CONFIDENTIAL? to each page that contains protected
24 || material. If only a portion or portions of the material on a page
25 qualifies for protection, the Producing Party also must clearly identify
6 Il the protected portion(s) (e.g., by making appropriate markings in the
27 margins).
28
1 A Party or Non-Party that makes original documents available for
2 || inspection need not designate them for protection until after the
3 || inspecting Party has indicated which documents it would like copied
4 || and produced. During the inspection and before the designation, all of
5 || the material made available for inspection shall be deemed
6 || CONFIDENTIAL. After the inspecting Party has identified the
7 || documents it wants copied and produced, the Producing Party must
8 || determine which documents, or portions thereof, qualify for protection
| under this Stipulated Protective Order. Then, before producing the
specified documents, the Producing Party must affix the
“CONFIDENTIAL” legend to each page that contains Protected
2 Material. If only a portion or portions of the material on a page
qualifies for protection, the Producing Party also must clearly identify
the protected portion(s) (e.g., by making appropriate markings in the
6 margins).
(b) for testimony given in depositions that the Designating Party
8 identify the Disclosure or Discovery Material on the record, before the
19 ||close of the deposition all protected testimony.
20 (c) for information produced in some form other than
31 ||documentary and for any other tangible items, that the Producing Party
22 ||affix in a prominent place on the exterior of the container or containers
23 ||in which the information is stored the “CONFIDENTIAL” legend. If only
24 ||a portion or portions of the information warrants protection, the
25 ||Producing Party, to the extent practicable, shall identify the protected
26 portion(s).
27 5.3 Inadvertent Failures to Designate. If timely corrected, an
28
1 || inadvertent failure to designate qualified information or items does not,
2 || standing alone, waive the Designating Party’s right to secure protection
3 || under this Order for such material. Upon timely correction of a
4 || designation, the Receiving Party must make reasonable efforts to assure
5 || that the material is treated in accordance with the provisions of this
6 || Stipulated Protective Order. Confidential documents produced before
7 filing this Stipulation by be designated “Confidential,” as provided
8 herein, and produced a second time, in which case those material will be
|| handled as though they had been originally produced with the
designation of “Confidential.” The documents produced initially without
the designation will be destroyed by the receiving party.
13
4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
15 6.1 ‘Timing of Challenges. Any Party or Non-Party may
16 || challenge a designation of confidentiality at any time that is consistent
17 || with the court’s Scheduling Order,
18 G2 Meet and Confer. The Challenging Party shall initiate the
19 || dispute resolution process under Local Rule 37.1 et seq.
20 6.3 The burden of persuasion in any such challenge proceeding
21 || shall be on the Designating Party. Frivolous challenges, and those
22 || made for an improper purpose (e.g., to harass or impose unnecessary
23 || expenses and burdens on other parties) may expose the Challenging
24 || Party to sanctions. Unless the Designating Party has waived or
25 || withdrawn the confidentiality designation, all parties shall continue to
26 |! afford the material in question the level of protection to which it is
27 || entitled under the Producing Party’s designation until the court rules on
28
1 || the challenge.
2
3 || 7 ACCESS TO AND USE OF PROTECTED MATERIAL
4 7.1 Basic Principles. A Receiving Party may use Protected
Material that is disclosed or produced by another Party or by a Non-
° Party in connection with this Action only for prosecuting, defending, or
’ attempting to settle this Action. Such Protected Material may be
disclosed only to the categories of persons and under the conditions
described in this Order. When the Action reaches a Final Disposition, a
Receiving Party must comply with the provisions of section 13 below.
Protected Material must be stored and maintained by a Receiving
3 Party at a location and in a secure manner that ensures that access is
4 limited to the persons authorized under this Stipulated Protective
|| Order.
16 7.2 Disclosure of “CONFIDENTIAL” Information or Items.
17 || Unless otherwise ordered by the court or permitted in writing by the
is || Designating Party, a Receiving Party may disclose any information or
19 || item designated “CONFIDENTIAL?” only:
20 (a) to the Receiving Party’s Outside Counsel of Record in this
21 || Action, as well as employees of said Outside Counsel of Record to whom
22 || it is reasonably necessary to disclose the information for this Action;
23 (b) to the officers, directors, and employees (including House
24 || Counsel) of the Receiving Party to whom disclosure is reasonably
25 necessary for this Action;
26 (c) to Experts (as defined in this Order) of the Receiving Party to
2” | whom disclosure is reasonably necessary for this Action and who have
28
1 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
2 (d) to the court and its personnel;
3 (e) to court reporters and their staff;
4 (f) to professional jury or trial consultants, mock jurors, and
5 || Professional Vendors to whom disclosure is reasonably necessary for
6 || this Action and who have signed the “Acknowledgment and Agreement
7 | to Be Bound” (Exhibit A);
8 (g) to the author or recipient of a document containing the
information or a custodian or other person who otherwise possessed or
knew the information;
(h) during their depositions, to witnesses, and attorneys for
2 witnesses, in the Action to whom disclosure is reasonably necessary,
provided: (1) the deposing party requests that the witness sign the
“Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
6 witness will not be permitted to keep any confidential information
unless they sign the “Acknowledgment and Agreement to Be Bound”
18 (Exhibit A), unless otherwise agreed by the Designating Party or
19 || ordered by the court. Pages of transcribed deposition testimony or
29 || exhibits to depositions that reveal Protected Material may be separately
21 || bound by the court reporter and may not be disclosed to anyone except
22 || as permitted under this 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
27
28
1 | 8 PROTECTED MATERIAL SUBPOENAED OR ORDERED
2 PRODUCED IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in
4 | other litigation that compels disclosure of any information or items
> designated in this Action as “CONFIDENTIAL,” that Party must:
(a) promptly notify in writing the Designating Party. Such
notification shall include a copy of the subpoena or court order;
9 (b) promptly notify in writing the party who caused the
10 subpoena or order to issue in the other litigation that some or all of the
11 || material covered by the subpoena or order is subject to this Protective
12 || Order. Such notification shall include a copy of this Stipulated
13. || Protective Order; and
14 (c) cooperate with respect to all reasonable procedures sought to
15 || be pursued by the Designating Party whose Protected Material may be
16 || affected.
17 If the Designating Party timely seeks a protective order, the
18 || Party served with the subpoena or court order shall not produce any
19 || information designated in this action as “CONFIDENTIAL?” before a
20 || determination by the court from which the subpoena or order issued,
21 |! unless the Party has obtained the Designating Party’s permission. The
22 Designating Party shall bear the burden and expense of seeking
23 protection in that court of its confidential material and nothing in these
provisions should be construed as authorizing or encouraging a
> Receiving Party in this Action to disobey a lawful directive from another
court.
27
28
1 || 9. ANON-PARTYS PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 9.1 Application. The terms of this Stipulated Protective Order
4 || are applicable to information produced by a Non-Party in this Action and
5 || designated as “CONFIDENTIAL.” Such information produced by Non-
6 || Parties in connection with this litigation is protected by the remedies
7 | and relief provided by this Order. Nothing in these provisions should be
8 || construed as prohibiting a Non-Party from seeking additional
protections.
9.2 Notification. In the event that a Party is required, by a valid
discovery request, to produce a Non-Party’s confidential information in
2 its possession, and the Party is subject to an agreement with the Non-
Party not to produce the Non-Party’s confidential information, then the
Party shall:
6 (a) promptly notify in writing the Requesting Party and the
Non-Party that some or all of the information requested is subject to a
8 confidentiality agreement with a Non-Party;
19 (b) make the information requested available for inspection by
29 || the Non-Party, if requested.
1 9.3 Conditions of Production. If the Non-Party fails to seek a
22 || protective order from this court within 14 days of receiving the notice
23 || and accompanying information, the Receiving Party may produce the
24 || Non-Party’s confidential information responsive to the discovery request.
25 || Ifthe Non-Party timely seeks a protective order, the Receiving Party
26 || shall not produce any information in its possession or control that is
27 || subject to the confidentiality agreement with the Non-Party before a
28 || determination by the court. Absent a court order to the contrary, the
1 || Non-Party shall bear the burden and expense of seeking protection in
2 || this court of its Protected Material.
3
4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
5 MATERIAL
° If a Receiving Party learns that, by inadvertence or otherwise, it
’ has disclosed Protected Material to any person or in any circumstance
not authorized under this Stipulated Protective Order, the Receiving
Party must immediately (a) notify in writing the Designating Party of
the unauthorized disclosures, (b) use its best efforts to retrieve all
unauthorized copies of the Protected Material, (c) inform the person or
13. || Persons to whom unauthorized disclosures were made of all the terms of
4 this Order, and (d) request such person or persons to execute the
is_|| ‘Acknowledgment and Agreement to Be Bound” (Exhibit A).
16
17 || 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
18 OTHERWISE PROTECTED MATERIAL
19 When a Producing Party gives notice to Receiving Parties that
70 certain inadvertently produced material is subject to a claim of privilege
or other protection, the obligations of the Receiving Parties are those set
°° forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This
° provision is not intended to modify whatever procedure may be
established in an e-discovery order that provides for production without
prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
4 Rules of Evidence, insofar as the parties reach an agreement on the
28 effect of disclosure of a communication or information covered by the
1 || attorney-client privilege or work product protection, the parties may
2 || incorporate their agreement in the stipulated protective order
3 || submitted to the court.
4
> || 12. MISCELLANEOUS
° 12.1 Right to Further Relief. Nothing in this Stipulated
’ Protective Order abridges the right of any person to seek its
modification by the court in the future.
12.2 Right to Assert Other Objections. By stipulating to the entry
of this Stipulated Protective Order no Party waives any right it
otherwise would have to object to disclosing or producing any
3 information or item on any ground not addressed in this Stipulated
4 Protective Order. Similarly, no Party waives any right to object on any
15 || ground to use in evidence of any of the material covered by this
ig || Stipulated Protective Order,
17 12.3 Filing Protected Material. A Party that seeks to file under
ig || seal any Protected Material must comply with Local Rule 79-5.
19 || Protected Material may only be filed under seal pursuant to a court
20 || order authorizing the sealing of the specific Protected Material at issue.
21 || Ifa Party's request to file Protected Material under seal is denied by the
22 || court, then the Receiving Party may file the information in the public
23 || record unless otherwise instructed by the court.
24
2 138. FINAL DISPOSITION
*° After the Final Disposition of this Action, as defined in paragraph
4, within 60 days of a written request by the Designating Party, each
1 || Receiving Party must return all Protected Material to the Producing
2 || Party or destroy such material. As used in this subdivision, “all
3 || Protected Material” includes all copies, abstracts, compilations,
4 || summaries, and any other format reproducing or capturing any of the
5 || Protected Material. Whether the Protected Material is returned or
6 || destroyed, the Receiving Party must submit a written certification to
7 the Producing Party (and, if not the same person or entity, to the
8 Designating Party) by the 60 day deadline that (1) identifies (by
category, where appropriate) all the Protected Material that was
returned or destroyed and (2) affirms that the Receiving Party has not
retained any copies, abstracts, compilations, summaries or any other
2 format reproducing or capturing any of the Protected Material.
Notwithstanding this provision, Counsel is entitled to retain an archival
copy of all pleadings, motion papers, trial, deposition, and hearing
6 transcripts, legal memoranda, correspondence, deposition and trial
exhibits, expert reports, attorney work product, and consultant and
8 expert work product, even if such materials contain Protected Material.
19 Any such archival copies that contain or constitute Protected Material
29 || remain subject to this Protective Order as set forth in Section 4.
21 | ///
UI
///
24
|| /
26 || ///
27 Jif
28
1 || 14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished
3 || by any and all appropriate measures including, without limitation,
4 || contempt proceedings and/or monetary sanctions.
5
6 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8 DATED: 6/30/2026 [atl any
Attorney(s) for Plaintiff(s)
10
DATED: __ 9/22/2026 Stan D. Pith
Attorney(s) for Defendant(s)
14
15
ig || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
18 DATED: July 6, 2026
19 DIANA M. Kwok
0 United States Magistrate Judge
21
22
23
24
25
26
27
28
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
° I, [print or type full name], of
‘ [print or type full address], declare under
penalty of perjury that I have read in its entirety and understand the
Stipulated Protective Order that was issued by the United States
District Court for the Central District of California on [date] in the
9 case of [insert formal name of the case and the
10 number and initials assigned to it by the court]. I agree to
comply with and to be bound by all the terms of this Stipulated
D Protective Order and I understand and acknowledge that failure to so
13 comply could expose me to sanctions and punishment in the nature of
14 contempt. I solemnly promise that I will not disclose in any manner
15 any information or item that is subject to this Stipulated Protective
16 Order to any person or entity except in strict compliance with the
17 provisions of this Order.
18 I further agree to submit to the jurisdiction of the United States
19 District Court for the Central District of California for the purpose of
20 enforcing the terms of this Stipulated Protective Order, even if such
21 enforcement proceedings occur after termination of this action. I
22 hereby appoint [print or type full name]
23 of [print or type full address and telephone number] as
24
25
26
27
28
1 my California agent for service of process in connection with this action
2 or any proceedings related to enforcement of this Stipulated Protective
3 Order.
4
5 Date:
6 City and State where sworn and
7 signed: TX
8 Printed name:
Signature:
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
An