Stepping Stones Group, LLC v. Community Roots Academy

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8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

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11 STEPPING STONES GROUP, LLC, a Case No. 8:22-cv-02286-JVS-DFM

Delaware limited liability company, as

12 successor-in-interest to FUTURES

EDUCATION, LLC, STIPULATED PROTECTIVE

13 ORDER

Plaintiff,

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v.

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COMMUNITY ROOTS ACADEMY,

16 Complaint Filed: December 21, 2022

Defendant. Trial Date: June 4, 2024

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18 COMMUNITY ROOTS ACADEMY,

19 Cross-Complainant,

20 v.

21 STEPPING STONES GROUP, LLC, a

Delaware limited liability company, as

22 successor-in-interest to FUTURES

EDUCATION, LLC; and DOES 1

23 through 10,

24 Counter-Defendants.

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1 1. A. PURPOSES AND LIMITATIONS

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

3 proprietary or private information for which special protection from public

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

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

6 enter the following Stipulated Protective Order. The parties acknowledge that this

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

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

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

10 under the applicable legal principles.

11 B. GOOD CAUSE STATEMENT

12 This action is likely to involve confidential, private and sensitive information,

13 concerning Non-Parties, students, and student families. The action is further likely

14 to involve trade secrets, customer and pricing lists and other valuable research,

15 development, commercial, financial, technical and/or proprietary information for

16 which special protection from public disclosure and from use for any purpose other

17 than prosecution of this action is warranted. Such confidential and proprietary

18 materials and information consist of, among other things, student records, student

19 family records, Non-Party records, confidential business or financial information,

20 information regarding confidential business practices, or other confidential research,

21 development, or commercial information (including information implicating privacy

22 rights of third parties), information otherwise generally unavailable to the public, or

23 which may be privileged or otherwise protected from disclosure under state or

24 federal statutes, court rules, case decisions, or common law. Accordingly, to

25 expedite the flow of information, to facilitate the prompt resolution of disputes over

26 confidentiality of discovery materials, to adequately protect information the parties

27 are entitled to keep confidential, to ensure that the parties are permitted reasonable

1 necessary uses of such material in preparation for and in the conduct of trial, to

2 address their handling at the end of the litigation, and serve the ends of justice, a

3 protective order for such information is justified in this matter. It is the intent of the

4 parties that information will not be designated as confidential for tactical reasons

5 and that nothing be so designated without a good faith belief that it has been

6 maintained in a confidential, non-public manner, and there is good cause why it

7 should not be part of the public record of this case.

8 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

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

10 Stipulated Protective Order does not entitle them to file confidential information

11 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed

12 and the standards that will be applied when a party seeks permission from the court

13 to file material under seal.

14 There is a strong presumption that the public has a right of access to judicial

15 proceedings and records in civil cases. In connection with non-dispositive motions,

16 good cause must be shown to support a filing under seal. See Kamakana v. City and

17 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors

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

19 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

20 require good cause showing), and a specific showing of good cause or compelling

21 reasons with proper evidentiary support and legal justification, must be made with

22 respect to Protected Material that a party seeks to file under seal. The parties’ mere

23 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

24 without the submission of competent evidence by declaration, establishing that the

25 material sought to be filed under seal qualifies as confidential, privileged, or

26 otherwise protectable—constitute good cause.

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

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

3 relief sought shall be narrowly tailored to serve the specific interest to be protected.

4 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For

5 each item or type of information, document, or thing sought to be filed or introduced

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

7 protection must articulate compelling reasons, supported by specific facts and legal

8 justification, for the requested sealing order. Again, competent evidence supporting

9 the application to file documents under seal must be provided by declaration.

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

11 its entirety will not be filed under seal if the confidential portions can be redacted.

12 If documents can be redacted, then a redacted version for public viewing, omitting

13 only the confidential, privileged, or otherwise protectable portions of the document,

14 shall be filed. Any application that seeks to file documents under seal in their

15 entirety should include an explanation of why redaction is not feasible.

16 2. DEFINITIONS

17 2.1 Action: Stepping Stones Group, LLC v. Community Roots Academy et

18 al. and related Counterclaim (8:22-cv-02286-JVS-DFM).

19 2.2 Challenging Party: a Party or Non-Party that challenges the

20 designation of information or items under this Order.

21 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

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

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

24 the Good Cause Statement.

25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

26 their support staff).

27 2.5 Designating Party: a Party or Non-Party that designates information or

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

2 “CONFIDENTIAL.”

3 2.6 Disclosure or Discovery Material: all items or information, regardless

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

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

6 generated in disclosures or responses to discovery or given in any testimony in this

7 matter.

8 2.7 Expert: a person with specialized knowledge or experience in a matter

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

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

11 2.8 House Counsel: attorneys who are employees of a Party to this Action.

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

13 counsel.

14 2.9 Non-Party: any natural person, partnership, corporation, association or

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

16 2.10 Outside Counsel of Record: attorneys who are not employees of a

17 Party to this Action but are retained to represent or advise a Party to this Action and

18 have appeared in this Action on behalf of that Party or are affiliated with a law firm

19 that has appeared on behalf of that Party, and includes support staff.

20 2.11 Party: any party to this Action, including all of its officers, directors,

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

22 support staffs).

23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

24 Discovery Material in this Action.

25 2.13 Professional Vendors: persons or entities that provide litigation

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

27 demonstrations, and organizing, storing, or retrieving data in any form or medium)

1 and their employees and subcontractors.

2 2.14 Protected Material: any Disclosure or Discovery Material that is

3 designated as “CONFIDENTIAL.”

4 2.15 Receiving Party: a Party that receives Disclosure or Discovery

5 Material from a Producing Party.

6 3. SCOPE

7 The protections conferred by this Stipulation and Order cover not only

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

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

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

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

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

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

14 4. DURATION

15 FINAL DISPOSITION of the action is defined as the conclusion of any

16 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal

17 has run. Except as set forth below, the terms of this protective order apply through

18 FINAL DISPOSITION of the action. The parties may stipulate that the they will be

19 contractually bound by the terms of this agreement beyond FINAL DISPOSITION,

20 but will have to file a separate action for enforcement of the agreement once all

21 proceedings in this case are complete.

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

23 CONFIDENTIAL or maintained pursuant to this protective order used or introduced

24 as an exhibit at trial becomes public and will be presumptively available to all

25 members of the public, including the press, unless compelling reasons supported by

26 specific factual findings to proceed otherwise are made to the trial judge in advance

27 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”

1 showing for sealing documents produced in discovery from “compelling reasons”

2 standard when merits-related documents are part of court record). Accordingly, for

3 such materials, the terms of this protective order do not extend beyond the

4 commencement of the trial.

5 5. DESIGNATING PROTECTED MATERIAL

6 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

9 that qualifies under the appropriate standards. The Designating Party must

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

11 written communications that qualify so that other portions of the material,

12 documents, items or communications for which protection is not warranted are not

13 swept unjustifiably within the ambit of this Order.

14 Mass, indiscriminate or routinized designations are prohibited. Designations

15 that are shown to be clearly unjustified or that have been made for an improper

16 purpose (e.g., to unnecessarily encumber the case development process or to impose

17 unnecessary expenses and burdens on other parties) may expose the Designating

18 Party to sanctions.

19 If it comes to a Designating Party’s attention that information or items that it

20 designated for protection do not qualify for protection, that Designating Party must

21 promptly notify all other Parties that it is withdrawing the inapplicable designation.

22 5.2 Manner and Timing of Designations. Except as otherwise provided in

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

24 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

25 under this Order must be clearly so designated before the material is disclosed or

26 produced.

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1 Designation in conformity with this Order requires:

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

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

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

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

6 contains protected material. If only a portion of the material on a page qualifies for

7 protection, the Producing Party also must clearly identify the protected portion(s)

8 (e.g., by making appropriate markings in the margins).

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

10 need not designate them for protection until after the inspecting Party has indicated

11 which documents it would like copied and produced. During the inspection and

12 before the designation, all of the material made available for inspection shall be

13 deemed “CONFIDENTIAL.” After the inspecting Party has identified the

14 documents it wants copied and produced, the Producing Party must determine which

15 documents, or portions thereof, qualify for protection under this Order. Then,

16 before producing the specified documents, the Producing Party must affix the

17 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a

18 portion of the material on a page qualifies for protection, the Producing Party also

19 must clearly identify the protected portion(s) (e.g., by making appropriate markings

20 in the margins).

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

22 on the record at the deposition, or within 10 days following receipt of the deposition

23 transcript, as protected testimony.

24 (c) for information produced in some form other than documentary and

25 for any other tangible items, that the Producing Party affix in a prominent place on

26 the exterior of the container or containers in which the information is stored the

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

1 warrants protection, the Producing Party, to the extent practicable, shall identify the

2 protected portion(s).

3 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

6 Upon timely correction of a designation, the Receiving Party must make reasonable

7 efforts to assure that the material is treated in accordance with the provisions of this

8 Order.

9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

10 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

12 Scheduling Order.

13 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

14 resolution process under Local Rule 37-1.

15 6.3 The burden of persuasion in any such challenge proceeding shall be on

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

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

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

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

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

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

22 challenge.

23 7. ACCESS TO AND USE OF PROTECTED MATERIAL

24 7.1 Basic Principles. A Receiving Party may use Protected Material that is

25 disclosed or produced by another Party or by a Non-Party in connection with this

26 Action only for prosecuting, defending or attempting to settle this Action. Such

27 Protected Material may be disclosed only to the categories of persons and under the

1 conditions described in this Order. When the Action has been terminated, a

2 Receiving Party must comply with the provisions of section 13 below (FINAL

3 DISPOSITION).

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

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

6 authorized under this Order.

7 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

9 Receiving Party may disclose any information or item designated

10 “CONFIDENTIAL” only to:

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

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

13 necessary to disclose the information for this Action;

14 (b) the officers, directors, and employees (including House Counsel) of

15 the Receiving Party to whom disclosure is reasonably necessary for this Action;

16 (c) Experts (as defined in this Order) of the Receiving Party to whom

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

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

19 (d) the court and its personnel;

20 (e) court reporters and their staff;

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

22 Vendors to whom disclosure is reasonably necessary for this Action and who have

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

24 (g) the author or recipient of a document containing the information or a

25 custodian or other person who otherwise possessed or knew the information;

26 (h) during their depositions, witnesses, and attorneys for witnesses, in the

27 Action to whom disclosure is reasonably necessary provided: (1) the deposing Party

1 requests that the witness sign the form attached as Exhibit A hereto; and (2) they

2 will not be permitted to keep any confidential information unless they sign the

3 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

4 agreed by the Designating Party or ordered by the court. Pages of transcribed

5 deposition testimony or exhibits to depositions that reveal Protected Material may

6 be separately bound by the court reporter and may not be disclosed to anyone except

7 as permitted under this Stipulated Protective Order; and

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

9 mutually agreed upon by any of the parties engaged in settlement discussions.

10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

11 IN OTHER LITIGATION

12 If a Party is served with a subpoena or a court order issued in other litigation

13 that compels disclosure of any information or items designated in this Action as

14 “CONFIDENTIAL,” that Party must:

15 (a) promptly notify in writing the Designating Party. Such notification

16 shall include a copy of the subpoena or court order;

17 (b) promptly notify in writing the Party who caused the subpoena or order

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

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

20 a copy of this Stipulated Protective Order; and

21 (c) cooperate with respect to all reasonable procedures sought to be

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

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

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

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

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

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

1 protection in that court of its confidential material and nothing in these provisions

2 should be construed as authorizing or encouraging a Receiving Party in this Action

3 to disobey a lawful directive from another court.

4 9. 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-Party

16 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 Action, 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, if requested.

23 (c) If the Non-Party fails to seek a protective order from this court within

24 14 days of receiving the notice and accompanying information, the Receiving Party

25 may produce the Non-Party’s confidential information responsive to the discovery

26 request. If the Non-Party timely seeks a protective order, the Receiving Party shall

27 not produce any information in its possession or control that is subject to the

1 confidentiality agreement with the Non-Party before a determination by the court.

2 Absent a court order to the contrary, the Non-Party shall bear the burden and

3 expense of seeking protection in this court of its Protected Material.

4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

6 Protected Material to any person or in any circumstance not authorized under this

7 Stipulated Protective Order, the Receiving Party must immediately (a) notify in

8 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

9 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

10 persons to whom unauthorized disclosures were made of all the terms of this Order,

11 and (d) request such person or persons to execute the “Acknowledgment and

12 Agreement to Be Bound” that is attached hereto as Exhibit A.

13 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

14 PROTECTED MATERIAL

15 When a Producing Party gives notice to Receiving Parties that certain

16 inadvertently produced material is subject to a claim of privilege or other protection,

17 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

18 Procedure 26(b)(5)(B). This provision is not intended to modify whatever

19 procedure may be established in an e-discovery order that provides for production

20 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and

21 (e), insofar as the parties reach an agreement on the effect of disclosure of a

22 communication or information covered by the attorney-client privilege or work

23 product protection, the parties may incorporate their agreement in the stipulated

24 protective order submitted to the court.

25 12. MISCELLANEOUS

26 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

27 person to seek its modification by the Court in the future.

1 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

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

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

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

12 13. FINAL DISPOSITION

13 After the final disposition of this Action, as defined in paragraph 4, within 60

14 days of a written request by the Designating Party, each Receiving Party must return

15 all Protected Material to the Producing Party or destroy such material. As used in

16 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

17 summaries, and any other format reproducing or capturing any of the Protected

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

19 Party must submit a written certification to the Producing Party (and, if not the same

20 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

21 (by category, where appropriate) all the Protected Material that was returned or

22 destroyed and (2) affirms that the Receiving Party has not retained any copies,

23 abstracts, compilations, summaries or any other format reproducing or capturing any

24 of the Protected Material. Notwithstanding this provision, Counsel are entitled to

25 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

26 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

27 reports, attorney work product, and consultant and expert work product, even if such

1 || materials contain Protected Material. Any such archival copies that contain or

2 || constitute Protected Material remain subject to this Protective Order as set forth in

3 || Section 4 (DURATION).

4 || 14. VIOLATION

5 Any violation of this Order may be punished by appropriate measures

6 || including, without limitation, contempt proceedings and/or monetary sanctions.

7 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

8 || DATED: June 2, 2023

9 || TROUTMAN PEPPER HAMILTON SANDERS LLP

10 || By: /s/Sevana Haroutunian

11_ || A: Christopher Young

Jeffrey M. Goldman

12 || Sevana Haroutunian

13 || Attorneys for Plaintiff and Counter-Defendant, THE STEPPING STONES GROUP

14 || DATED: June 2, 2023

15 || SHEPPARD MULLIN RICHTER & HAMPTON LLP

16 || By: /s/Aaron J. Malo!

17 || Aaron J. Malo

Jason A. Weiss

18 Tyler Z. Bernstein

19 || Attorneys for Defendant and Counterclaimant, COMMUNITY ROOTS CHARTER

50 SCHOOL dba COMMUNITY ROOTS ACADEMY

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

22 || DATED: June 5, 2023

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95 || HON. BOUGLAS F. MCCORMICK

United States Magistrate Judge

26

27 os

' Pursuant to Local Rule 5-4.3.4(a)(2)(i), the filer attests that all other signatories listed, and on

28 || whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing.

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, __________________________ [print or type full name], of _________________

4 [print or type full address], declare under penalty of perjury that I have read in its

5 entirety and understand the Stipulated Protective Order that was issued by the

6 United States District Court for the Central District of California on _____________

7 in the case of Stepping Stones Group, LLC v. Community Roots Academy et al.

8 (8:22-cv-02286-JVS-DFM). I agree to comply with and to be bound by all the

9 terms of this Stipulated Protective Order and I understand and acknowledge that

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

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

12 information or item that is subject to this Stipulated Protective Order to any person

13 or entity except in strict compliance with the provisions of this Order.

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

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

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

17 I hereby appoint __________________________ [print or type full name] of

18 _______________________________________ [print or type full address and

19 telephone number] as my California agent for service of process in connection with

20 this action or any proceedings related to enforcement of this Stipulated Protective

21 Order.

22 Date: ______________________________________

23 City and State where sworn and signed: _________________________________

24 Printed name: _______________________________

25

26 Signature: __________________________________

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