Opinion

Andres Catalan v. Koki Holdings America, Ltd.

Court: District Court, C.D. California
Filed: Dec 12, 2022
Cited by: 0 cases
Authority: More cited than 16.4%

even stipulated protective orders require good cause showing

How later courts described this case

even stipulated protective orders require good cause showing

Written by the judges who cited it.

The opinion

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STIPULATED PROTECTIVE ORDER

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JEFFREY A. SWEDO (SBN: 78361)

jswedo@grsm.com

RAYMOND L. GILL (SBN: 153529)

rgill@grsm.com

PAMELA J. SILK (SBN: 179359)

psilk@grsm.com

GORDON REES SCULLY MANSUKHANI, LLP

5 Park Plaza, Suite 1100

Irvine, CA 92614

Telephone: (949) 255-6981

Facsimile: (949) 474-2060

Attorneys for Defendant

KOKI HOLDINGS AMERICA LTD.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

ANDRES CATALAN, ) Case No.: 2:21-cv-01451 MWF

) (AFMx)

Plaintiff, )

)

vs. ) STIPULATED PROTECTIVE

ORDER1

)

KOKI HOLDINGS AMERICA, Ltd.,

)

aka METABO HPT, a Delaware

Corporation; HITACHI KOKI, Ltd., a )

Japanese Corporation; TRADEMARK )

CONSTRUCTION CO., Inc., aka J.M. )

Truss and Components, an Arizona )

Corporation; WK CK SHERMAN )

OAKS VENTURE, LLC, a Delaware )

Corporation; CARPENTERS )

SOUTHWEST ADMINISTRATIVE )

CORPORATION, a California )

corporation; and DOES 1 to 20, )

Inclusive, )

) Defendants.

1. A. PURPOSES AND LIMITATIONS

Discovery in this action is likely to involve production of confidential,

proprietary or private information for which special protection from public

disclosure and from use for any purpose other than prosecuting this litigation may

1 This Stipulated Protective Order is based substantially on the model protective order provided

under Magistrate Judge Alexander F. MacKinnon’s Procedures.

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be warranted. Accordingly, the parties hereby stipulate to and petition the Court

to enter the following Stipulated Protective Order. The parties acknowledge that

this Order does not confer blanket protections on all disclosures or responses to

discovery and that the protection it affords from public disclosure and use extends

only to the limited information or items that are entitled to confidential treatment

under the applicable legal principles.

B. GOOD CAUSE STATEMENT

This action involves a product liability claim pertaining to a Hitachi NR83A3

nailer distributed by Defendant Koki Holdings America Ltd. Plaintiff’s discovery

pertains to documents involving the design, manufacture, testing, and recall

campaign servicing of said product. These documents are considered to be

proprietary trade secrets of Defendant, and these documents are not in the public

domain. These documents, if discovered by Koki’s competitors, could be used to

facilitate copying of designs and processes for this product. Some documents

pertain to the servicing of these nailers following a recall, which was handled

exclusively by Defendant. Among the reasons that only the Defendant performed

the recall servicing procedures was to ensure that the procedures were performed

with 100% complete accuracy. This was done out of concern as third party repairs

may not have been done properly and the quality of those repairs could not be

assured. Other documents pertaining to servicing of the product contain the

institutional “know how” of Defendant and is not information in the public

domain. Releasing this information would put Defendant at a competitive

disadvantage in its role as a service center for the repair and maintenance of

Hitachi tools, including the subject product.

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

other valuable research, development, commercial, financial, technical and/or

proprietary information for which special protection from public disclosure and

from use for any purpose other than prosecution of this action is warranted. Such

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confidential and proprietary materials and information consist of, among other

things, confidential business or financial information, information regarding

confidential business practices, or other confidential research, development, or

commercial information (including information implicating privacy rights of third

parties), information otherwise generally unavailable to the public, or which may

be privileged or otherwise protected from disclosure under state or federal statutes,

court rules, case decisions, or common law. Accordingly, to expedite the flow of

information, to facilitate the prompt resolution of disputes over confidentiality of

discovery materials, to adequately protect information the parties are entitled to

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

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

handling at the end of the litigation, and serve the ends of justice, a protective order

for such information is justified in this matter. It is the intent of the parties that

information will not be designated as confidential for tactical reasons and that

nothing be so designated without a good faith belief that it has been maintained in

a confidential, non-public manner, and there is good cause why it should not be

part of the public record of this case.

C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER

SEAL

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

this Stipulated Protective Order does not entitle them to file confidential

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

be followed and the standards that will be applied when a party seeks permission

from the court to file material under seal.

There is a strong presumption that the public has a right of access 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 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v.

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Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v.

Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated

protective orders require good cause showing), and a specific showing of good

cause or compelling reasons with proper evidentiary support and legal

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

file under seal. The parties’ mere designation of Disclosure or Discovery Material

as CONFIDENTIAL does not—without the submission of competent evidence by

declaration, establishing that the material sought to be filed under seal qualifies as

confidential, privileged, or otherwise protectable—constitute good cause.

Further, if a party requests sealing related to a dispositive motion or trial,

then compelling reasons, not only good cause, for the sealing must be shown, and

the relief sought shall be narrowly tailored to serve the specific interest to be

protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir.

2010). For each item or type of information, document, or thing sought to be filed

or introduced under seal in connection with a dispositive motion or trial, the party

seeking protection must articulate compelling reasons, supported by specific facts

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

supporting the application to file documents under seal must be provided by

declaration.

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

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

2. DEFINITIONS

2.1 Action: Andres Catalan vs. Koki Holdings America Ltd., et al.,

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United States District Court Case No. 2:21-cv-01451 MWF (AFMx).

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

designation of information or items under this Order.

2.3 “CONFIDENTIAL” Information or Items: information (regardless of

how it is generated, stored or maintained) or tangible things that qualify for

protection under Federal Rule of Civil Procedure 26(c), and as specified above in

the Good Cause Statement.

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

their support staff).

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

or items that it produces in disclosures or in responses to discovery as

“CONFIDENTIAL.”

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

of the medium or manner in which it is generated, stored, or maintained (including,

among other things, testimony, transcripts, and tangible things), that are produced

or generated in disclosures or responses to discovery in this matter.

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

pertinent to the litigation who has been retained by a Party or its counsel to serve

as an expert witness or as a consultant in this Action.

2.8 House Counsel: attorneys who are employees of a party to this Action.

House Counsel does not include Outside Counsel of Record or any other outside

counsel.

2.9 Non-Party: any natural person, partnership, corporation, association

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

2.10 Outside Counsel of Record: attorneys who are not employees of a

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

and have appeared in this Action on behalf of that party or are affiliated with a law

firm that has appeared on behalf of that party, and includes support staff.

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STIPULATED PROTECTIVE ORDER

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2.11 Party: any party to this Action, including all of its officers, directors,

employees, consultants, retained experts, and Outside Counsel of Record (and

their support staffs).

2.12 Producing Party: a Party or Non-Party that produces Disclosure or

Discovery Material in this Action.

2.13 Professional Vendors: persons or entities that provide litigation

support services (e.g., photocopying, videotaping, translating, preparing exhibits

or demonstrations, and organizing, storing, or retrieving data in any form or

medium) and their employees and subcontractors.

2.14 Protected Material: any Disclosure or Discovery Material that is

designated as “CONFIDENTIAL.”

2.15 Receiving Party: a Party that receives Disclosure or Discovery

Material from a Producing Party.

3. SCOPE

The protections conferred by this Stipulation and Order cover not only

Protected Material (as defined above), but also (1) any information copied or

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

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

presentations by Parties or their Counsel that might reveal Protected Material.

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

trial judge. This Order does not govern the use of Protected Material at trial.

4. DURATION

Once a case proceeds to trial, information that was designated as

CONFIDENTIAL or maintained pursuant to this protective order used or

introduced as an exhibit at trial becomes public and will be presumptively

available to all members of the public, including the press, unless compelling

reasons supported by specific factual findings to proceed otherwise are made to

the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81

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(distinguishing “good cause” showing for sealing documents produced in

discovery from “compelling reasons” standard when merits-related documents are

part of court record). Accordingly, the terms of this protective order do not extend

beyond the commencement of the trial.

5. DESIGNATING PROTECTED MATERIAL

5.1 Exercise of Restraint and Care in Designating Material for Protection.

Each Party or Non-Party that designates information or items for protection under

this Order must take care to limit any such designation to specific material that

qualifies under the appropriate standards. The Designating Party must designate

for protection only those parts of material, documents, items or oral or written

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

items or communications for which protection is not warranted are not swept

unjustifiably within the ambit of this Order.

Mass, indiscriminate or routinized designations are prohibited.

Designations that are shown to be clearly unjustified or that have been made for

an improper purpose (e.g., to unnecessarily encumber the case development

process or to impose unnecessary expenses and burdens on other parties) may

expose the Designating Party to sanctions.

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

this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

stipulated or ordered, Disclosure or Discovery Material that qualifies for

protection under this Order must be clearly so designated before the material is

disclosed or produced.

Designation in conformity with this Order requires:

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

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

proceedings), that the Producing Party affix at a minimum, the legend

“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

contains protected material. If only a portion 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 margins).

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

inspection need not designate them for protection until after the inspecting Party

has indicated which documents it would like copied and produced. During the

inspection and before the designation, all of the material made available for

inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has

identified the documents it wants copied and produced, the Producing Party must

determine which documents, or portions thereof, qualify for protection under this

Order. Then, before producing the specified documents, the Producing Party must

affix the “CONFIDENTIAL legend” to each page that contains Protected Material.

If only a portion 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 margins).

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

identifies the Disclosure or Discovery Material on the record, before the close of

the deposition all protected testimony.

and for any other tangible items, that the Producing Party affix in a prominent

place on the exterior of the container or containers in which the information is

stored the legend “CONFIDENTIAL.” If only a portion or portions of the

information warrants protection, the Producing Party, to the extent practicable,

shall identify the protected portion(s).

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

failure to designate qualified information or items does not, standing alone, waive

the Designating Party’s right to secure protection under this Order for such

material. Upon timely correction of a designation, the Receiving Party must make

reasonable efforts to assure that the material is treated in accordance with the

provisions of this Order.

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

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

designation of confidentiality at any time that is consistent with the Court’s

Scheduling Order.

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

resolution process under Local Rule 37-1 et seq.

6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a

joint stipulation pursuant to Local Rule 37-2.

6.4 The burden of persuasion in any such challenge proceeding shall be

on the Designating Party. Frivolous challenges, and those made for an improper

purpose (e.g., to harass or impose unnecessary expenses and burdens on other

parties) may expose the Challenging Party to sanctions. Unless the Designating

Party has waived or withdrawn the confidentiality designation, all parties shall

continue to afford the material in question the level of protection to which it is

entitled under the Producing Party’s designation until the Court rules on the

challenge.

7. ACCESS TO AND USE OF PROTECTED MATERIAL

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 has been

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terminated, a Receiving Party must comply with the provisions of section 13 below

(FINAL DISPOSITION).

Protected Material must be stored and maintained by a Receiving Party at a

location and in a secure manner that ensures that access is limited to the persons

authorized under this Order.

7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

otherwise ordered by the court or permitted in writing by the Designating Party, a

Receiving Party may disclose any information or item designated

“CONFIDENTIAL” only to:

(a) the Receiving Party’s Outside Counsel of Record in this Action,

as well as employees of said Outside Counsel of Record to whom it is reasonably

necessary to disclose the information for this Action;

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

Counsel) of the Receiving Party to whom disclosure is reasonably necessary for

this Action;

whom disclosure is reasonably necessary for this Action and who have signed the

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

(d) the court and its personnel;

(e) court reporters and their staff;

(f) professional jury or trial consultants, mock jurors, and

Professional Vendors to whom disclosure is reasonably necessary for this Action

and who have signed the “Acknowledgment and Agreement to Be Bound”

(Exhibit A);

(g) 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, witnesses, and attorneys for witnesses,

in the Action to whom disclosure is reasonably necessary provided: (1) the

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deposing party requests that the witness sign the form attached as Exhibit 1 hereto;

and (2) they will not be permitted to keep any confidential information unless they

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

otherwise agreed by the Designating Party or ordered by the court. Pages of

transcribed deposition testimony or exhibits to depositions that reveal Protected

Material may be separately bound by the court reporter and may not be disclosed

to anyone except as permitted under this Stipulated Protective Order; and

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

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

discussions.

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

IN OTHER LITIGATION

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

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

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

the subpoena or order is subject to this Protective Order. Such notification shall

include a copy of this Stipulated Protective Order; and

pursued by the Designating Party whose Protected Material may be affected.

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

with the subpoena or court order shall not produce any information designated in

this action as “CONFIDENTIAL” before a determination by the court from which

the subpoena or order issued, unless the Party has obtained the Designating Party’s

permission. The Designating Party shall bear the burden and expense of seeking

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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.

9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

PRODUCED IN THIS LITIGATION

(a) The terms of this Order are applicable to information produced

by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such

information produced by Non-Parties in connection with this litigation is protected

by the remedies and relief provided by this Order. Nothing in these provisions

should be construed as prohibiting a Non-Party from seeking additional

protections.

(b) In the event that a Party is required, by a valid discovery request,

to produce a Non-Party’s confidential information in 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:

(1) promptly notify in writing the Requesting Party and the

Non-Party that some or all of the information requested is subject to a

confidentiality agreement with a Non-Party;

(2) promptly provide the Non-Party with a copy of the

Stipulated Protective Order in this Action, the relevant discovery request(s), and a

reasonably specific description of the information requested; and

(3) make the information requested available for inspection

by the Non-Party, if requested.

within 14 days of receiving the notice and accompanying information, the

Receiving Party may produce the Non-Party’s confidential information responsive

to the discovery request. If the Non-Party timely seeks a protective order, the

Receiving Party shall not produce any information in its possession or control that

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is subject to the confidentiality agreement with the Non-Party before a

determination by the court. Absent a court order to the contrary, the Non-Party

shall bear the burden and expense of seeking protection in this court of its

Protected Material.

10. UNAUTHORIZED DISCLOSURE OF PROTECTED 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 persons to whom unauthorized disclosures were made of all the terms

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

“Acknowledgment and Agreement to Be Bound” that is attached hereto as

Exhibit A.

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that 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 Federal

Rule of Civil Procedure 26(b)(5)(B). 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 Federal Rule of Evidence

502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

of a communication or information covered by the attorney-client privilege or

work product protection, the parties may incorporate their agreement in the

stipulated protective order submitted to the court.

12. MISCELLANEOUS

12.1 Right to Further Relief. Nothing in this Order abridges the right of

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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

Protective Order, no Party waives any right it otherwise would have to object to

disclosing or producing any information or item on any ground not addressed in

this Stipulated Protective Order. Similarly, no Party waives any right to object on

any ground to use in evidence of any of the material covered by this Protective

Order.

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

Protected Material must comply with Local Civil Rule 79-5. Protected Material

may only be filed under seal pursuant to a court order authorizing the sealing of

the specific Protected Material at issue. If a Party’s request to file Protected

Material under seal is denied by the court, then the Receiving Party may file the

information in the public record unless otherwise instructed by the court.

13. 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 Receiving Party must

return all Protected Material to the Producing Party or destroy such material. As

used in this subdivision, “all Protected Material” includes all copies, abstracts,

compilations, summaries, and any other format reproducing or capturing any of

the Protected Material. Whether the Protected Material is returned or destroyed,

the Receiving Party must submit a written certification to the Producing Party

(and, if not the same person or entity, to the 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

format reproducing or capturing any of the Protected Material. Notwithstanding

this provision, Counsel are entitled to retain an archival copy of all pleadings,

motion papers, trial, deposition, and hearing transcripts, legal memoranda,

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correspondence, deposition and trial exhibits, expert reports, attorney work

product, and consultant and expert work product, even if such materials contain

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

Material remain subject to this Protective Order as set forth in Section 4

(DURATION).

14. VIOLATION

Any violation of this Order may be punished by appropriate measures including,

without limitation, contempt proceedings and/or monetary sanctions.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

Dated: November 16, 2022 REYES & ASSOCIATES, P.C.

By: /s/ Jorge H. Reyes

Jorge H. Reyes

Attorneys for Plaintiff

ANDRES CATALAN

Dated: November 16, 2022 LAW OFFICES OF MARK RAVIS

& ASSOCIATES

By: /s/ Mark Ravis

Mark Ravis

Attorneys for Plaintiff

ANDRES CATALAN

Dated: September 20, 2022 GORDON REES SCULLY

MANSUKHANI, LLP

By: /s/ Jeffrey A. Swedo

Jeffrey A. Swedo

Attorneys for Defendant KOKI

HOLDINGS, INC.

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l SIGNATURE CERTIFICATION

2 I, Jeffrey A. Swedo, hereby attest pursuant to Civil Local Rule 5-4.3.4 that

3 || all signatories listed, and on whose behalf this filing is submitted, concur in the

4 || contents of this filing and have authorized the filing.

5 Executed this 16" day of November, 2022, at Newport Beach, California.

/s/_ Jeffrey A. Swedo

7 Jeffrey A. Swedo

de 12

13 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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DATED: 12/12/2022

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20 HON. ALEXANDER F. MacKINNON

21 || United States Magistrate Judge

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STIPULATED PROTECTIVE ORDER

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STIPULATED PROTECTIVE ORDER

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Case 2:21-cv-01451-MWF-AFM Document 77 Filed 12/12/22 Page 17 of 17 Page ID #:957

EXHIBIT A

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 ____________________, 2022 [date] in

the case of Andres Catalan vs. Koki Holdings America Ltd., et al., United States District

Court Case No. 2:21-cv-01451 MWF (AFMx). I agree to comply with and to be bound

by all the terms of this Stipulated Protective Order and I understand and acknowledge

that failure to so comply could expose me to sanctions and punishment in the nature of

contempt. I solemnly promise that I will not disclose in any manner any information or

item that is subject to this Stipulated Protective Order to any person or entity except in

strict compliance with the provisions of this Order.

I further agree to submit to the jurisdiction of the United States District Court for

the Central District of California for enforcing the terms of this Stipulated Protective

Order, even if such enforcement proceedings occur after termination of this action.

I hereby appoint _____________________ [print or type full name] of

_________________________________________________________________ [print

or type full address and telephone number] as my California agent for service of process

in connection with this action or any proceedings related to enforcement of this

Stipulated Protective Order.

Date:

City and State where sworn and signed:

Printed name:

Signature:

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