# Adrian Zavala v. First Advantage Background Services Corp.

> District Court, C.D. California · August 16, 2023

URL: https://www.frixlaw.com/law-library/cases/9984126

## Case

- **Court:** District Court, C.D. California
- **Decided:** August 16, 2023
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

Youssef H. Hammoud, CA Bar No. 321934
1
Email: yh@lawhammoud.com
2 HAMMOUD LAW, P.C
3 3744 East Chapman Avenue, #F12269
Orange, California 92859
4 Telephone: (949) 301-9692
5 Facsimile: (949) 301-9693
Attorney for Plaintiff
6
Adrian Zavala
7
UNITED STATES DISTRICT COURT
8
FOR THE CENTRAL DISTRICT OF CALIFORNIA
9 LOS ANGELES DIVISION

10
ADRIAN ZAVALA,
11 Case No.: 2:23-cv-02637-SPG-PD
12 Plaintiff,

13 STIPULATED PROTECTIVE
14
vs. ORDER1

15 FIRST ADVANTAGE BACKGROUND
16 SERVICES CORP.

17
Defendants.
18

19
1. A. PURPOSES AND LIMITATIONS
20
21 Discovery in this action is likely to involve production of confidential,
proprietary, or private information for which special protection from public disclosure
22 and from use for any purpose other than prosecuting this litigation may be warranted.
23 Accordingly, the parties hereby stipulate to and petition the Court to enter the
following Stipulated Protective Order. The parties acknowledge that this Order does
24 not confer blanket protections on all disclosures or responses to discovery and that the
25 protection it affords from public disclosure and use extends only to the limited
26

27 1 This Stipulated Protective Order is substantially based on the model protective order
28
provided under Magistrate Judge Patricia Donahue’s Procedures.
information or items that are entitled to confidential treatment under the applicable
1
legal principles.
2
B. GOOD CAUSE STATEMENT
3
4 This action is likely to involve trade secrets, cost and pricing information and
other valuable commercial, financial, technical and/or proprietary information for
5
which special protection from public disclosure and from use for any purpose other
6 than prosecution of this action is warranted. This action will also likely involve
consumer protected personal information. Such confidential and proprietary materials
7
and information consist of, among other things, confidential business or financial
8 information, information regarding confidential business practices, or other
confidential commercial information (including information implicating privacy rights
9
of third parties), information otherwise generally unavailable to the public, or which
10 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
11
of information, to facilitate the prompt resolution of disputes over confidentiality of
12 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
13
material in preparation for and in the conduct of trial, to address their handling at the
14 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
15
not be designated as confidential for tactical reasons and that nothing be so designated
16 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
17 case.
18
C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
19
The parties further acknowledge, as set forth in Section 12.3, below, that this
20
Stipulated Protective Order does not entitle them to file confidential information under
21 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
22
material under seal.
23
There is a strong presumption that the public has a right of access to judicial
24
proceedings and records in civil cases. In connection with non-dispositive motions,
25 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. Gen. Motors
26
Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,
27 187 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
28
proper evidentiary support and legal justification, must be made with respect to
1
Protected Material that a party seeks to file under seal. The parties’ mere designation
2 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the
submission of competent evidence by declaration, establishing that the material sought
3
to be filed under seal qualifies as confidential, privileged, or otherwise protectable—
4 constitute good cause.
5
Further, if a party requests sealing related to a dispositive motion or trial, then
6 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
7
Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
8 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
9
articulate compelling reasons, supported by specific facts and legal justification, for
10 the requested sealing order. Again, competent evidence supporting the application to
file documents under seal must be provided by declaration.
11
12 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
13
documents can be redacted, then a redacted version for public viewing, omitting only
14 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
15
include an explanation of why redaction is not feasible.
16
2. DEFINITIONS
17
2.1 Action: this pending federal lawsuit.
18
19 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
information or items under this Order.
20
21 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is
generated, stored or maintained) or tangible things that qualify for protection under
22
Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
23 Statement.
24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
25 support staff).
26 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.”
27
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2.6 Disclosure or Discovery Material: all items or information, regardless of the
1
medium or manner in which it is generated, stored, or maintained (including, among
2 other things, testimony, transcripts, and tangible things), that are produced or generated
in disclosures or responses to discovery in this matter.
3
4 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
5
witness or as a consultant in this Action.
6
2.8 House Counsel: attorneys who are employees of a party to this Action. House
7
Counsel does not include Outside Counsel of Record or any other outside counsel.
8
2.9 Non-Party: any natural person, partnership, corporation, association, or other
9 legal entity not named as a Party to this action.
10
2.10 Outside Counsel of Record: attorneys who are not employees of a party to this
11 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 which has
12
appeared on behalf of that party, and includes support staff.
13
2.11 Party: any party to this Action, including all of its officers, directors,
14
employees, consultants, retained experts, and Outside Counsel of Record (and their
15 support staffs).
16
2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
17 Material in this Action.
18 2.13 Professional Vendors: persons or entities that provide litigation support
19 services (e.g., photocopying, videotaping, translating, preparing exhibits or
demonstrations, and organizing, storing, or retrieving data in any form or medium) and
20 their employees and subcontractors.
21
2.14 Protected Material: any Disclosure or Discovery Material that is designated as
22 “CONFIDENTIAL.”
23
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from
24 a Producing Party.
25
3. SCOPE
26
The protections conferred by this Stipulation and Order cover not only Protected
27
Material (as defined above), but also (1) any information copied or extracted from
28
Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
1
Material; and (3) any testimony, conversations, or presentations by Parties or their
2 Counsel that might reveal Protected Material.
3
Any use of Protected Material at trial shall be governed by the orders of the trial
4 judge. This Order does not govern the use of Protected Material at trial.
5
4. DURATION
6
FINAL DISPOSITION of the action is defined as the conclusion of any
7 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal
8 has run. Except as set forth below, the terms of this protective order apply through
FINAL DISPOSITION of the action. The parties may stipulate that the they will be
9 contractually bound by the terms of this agreement beyond FINAL DISPOSITION,
10 but will have to file a separate action for enforcement of the agreement once all
proceedings in this case are complete.
11
Once a case proceeds to trial, information that was designated as
12
CONFIDENTIAL or maintained pursuant to this protective order used or introduced
13 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
14
factual findings to proceed otherwise are made to the trial judge in advance of the trial.
15 See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing
documents produced in discovery from “compelling reasons” standard when merits-
16
related documents are part of court record). Accordingly, for such materials, the terms
17 of this protective order do not extend beyond the commencement of the trial.
18
5. DESIGNATING PROTECTED MATERIAL
19
5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
20
Party or Non-Party that designates information or items for protection under this Order
21 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
22
those parts of material, documents, items, or oral or written communications that
23 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
24
Order.
25
Mass, indiscriminate, or routinized designations are prohibited. Designations that
26 are shown to be clearly unjustified or that have been made for an improper purpose
27 (e.g., to unnecessarily encumber the case development process or to impose
28
unnecessary expenses and burdens on other parties) may expose the Designating Party
1
to sanctions.
2
If it comes to a Designating Party’s attention that information or items that it
3
designated for protection do not qualify for protection, that Designating Party must
4 promptly notify all other Parties that it is withdrawing the inapplicable designation.
5
5.2 Manner and Timing of Designations. Except as otherwise provided in this Order
6 (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
7
must be clearly so designated before the material is disclosed or produced.
8
Designation in conformity with this Order requires:
9
10
(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
11 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
“CONFIDENTIAL legend”), to each page that contains protected material. If only a
12
portion or portions of the material on a page qualifies for protection, the Producing
13 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
markings in the margins).
14
15 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
16
which documents it would like copied and produced. During the inspection and before
17 the designation, all of the material made available for inspection shall be deemed
“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
18
copied and produced, the Producing Party must determine which documents, or
19 portions thereof, qualify for protection under this Order. Then, before producing the
specified documents, the Producing Party must affix the “CONFIDENTIAL legend”
20
to each page that contains Protected Material. If only a portion or portions of the
21 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).
22
23 (b) for testimony given in depositions, that the Designating Party identify the
Disclosure or Discovery Material on the record, or, within 30 days of the close of the
24
deposition, identify all protected testimony.
25
(c) for information produced in some form other than documentary and for any other
26 tangible items, that the Producing Party affix in a prominent place on the exterior of the
27 container or containers in which the information is stored the legend
“CONFIDENTIAL.” If only a portion or portions of the information warrants
28
protection, the Producing Party, to the extent practicable, shall identify the protected
1
portion(s).
2
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
3
designate qualified information or items does not, standing alone, waive the
4 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
5
assure that the material is treated in accordance with the provisions of this Order.
6
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
7
8 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.
9
6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
10
process under Local Rule 37.1 et seq.
11
6.3 The burden of persuasion in any such challenge proceeding shall be on the
12
Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
13 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
14
withdrawn the confidentiality designation, all parties shall continue to afford the
15 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.
16
17 7. ACCESS TO AND USE OF PROTECTED MATERIAL
18 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed
19 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
20 may be disclosed only to the categories of persons and under the conditions described
21 in this Order. When the Action has been terminated, a Receiving Party must comply
with the provisions of section 13 below (FINAL DISPOSITION).
22
23 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
24 under this Order.
25
7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
26 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:
27
28
(a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
1
employees of said Outside Counsel of Record to whom it is reasonably necessary to
2 disclose the information for this Action;
3
(b) the officers, directors, and employees (including House Counsel) of the
4 Receiving Party to whom disclosure is reasonably necessary for this Action;
5
(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
6 reasonably necessary for this Action and who have signed the “Acknowledgment and
Agreement to Be Bound” (Exhibit A);
7
8 (d) the court and its personnel;
9 (e) court reporters and their staff;
10
(f) professional jury or trial consultants, mock jurors, and Professional Vendors to
11 whom disclosure is reasonably necessary for this Action and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
12
13 (g) the author or recipient of a document containing the information or a custodian
or other person who otherwise possessed or knew the information;
14
15 (h) during their depositions, witnesses ,and attorneys for witnesses, in the Action to
whom disclosure is reasonably necessary provided: (1) the deposing party requests that
16
the witness sign the form attached as Exhibit 1 hereto; and (2) they will not be
17 permitted to keep any confidential information unless they sign the “Acknowledgment
and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating
18 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to
19 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
20 Protective Order; and
21
(i) any mediator or settlement officer, and their supporting personnel, mutually
22 agreed upon by any of the parties engaged in settlement discussions.
23
8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
24 OTHER LITIGATION
25
If a Party is served with a subpoena or a court order issued in other litigation
26 that compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL,” that Party must:
27
28
(a) promptly notify in writing the Designating Party. Such notification shall include
1
a copy of the subpoena or court order;
2
(b) promptly notify in writing the party who caused the subpoena or order to issue
3
in the other litigation that some or all of the material covered by the subpoena or order
4 is subject to this Protective Order. Such notification shall include a copy of this
Stipulated Protective Order; and
5
6 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
Designating Party whose Protected Material may be affected.
7
8 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
9 as “CONFIDENTIAL” before a determination by the court from which the subpoena
10 or order issued, unless the Party has obtained the Designating Party’s permission. The
Designating Party shall bear the burden and expense of seeking protection in that court
11 of its confidential material and nothing in these provisions should be construed as
12 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
directive from another court.
13
9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
14
PRODUCED IN THIS LITIGATION
15
(a) The terms of this Order are applicable to information produced by a Non-Party
16
in this Action and designated as “CONFIDENTIAL.” Such information produced by
17 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
18
a Non-Party from seeking additional protections.
19
(b) In the event that a Party is required, by a valid discovery request, to produce a
20
Non-Party’s confidential information in its possession, and the Party is subject to an
21 agreement with the Non-Party not to produce the Non-Party’s confidential
information, then the Party shall:
22
23 (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
24 with a Non-Party;
25
(2) promptly provide the Non-Party with a copy of the Stipulated Protective
26 Order in this Action, the relevant discovery request(s), and a reasonably specific
description of the information requested; and
27
28
(3) make the information requested available for inspection by the Non-
1
Party, if requested.
2
(c) If the Non-Party fails to seek a protective order from this court within 14 days
3
of receiving the notice and accompanying information, the Receiving Party may
4 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
5
any information in its possession or control that is subject to the confidentiality
6 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
7
in this court of its Protected Material.
8
10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
9
10 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
11 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
12 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
13 whom unauthorized disclosures were made of all the terms of this Order, and (d)
14 request such person or persons to execute the “Acknowledgment and Agreement to Be
Bound” that is attached hereto as Exhibit A.
15
11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
16
PROTECTED MATERIAL
17
When a Producing Party gives notice to Receiving Parties that certain
18
inadvertently produced material is subject to a claim of privilege or other protection,
19 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
20
may be established in an e-discovery order that provides for production without prior
21 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
22
information covered by the attorney-client privilege or work product protection, the
23 parties may incorporate their agreement in the stipulated protective order submitted to
the court.
24
25 12. MISCELLANEOUS
26 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person
27 to seek its modification by the Court in the future.
28
12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective
1
Order no Party waives any right it otherwise would have to object to disclosing or
2 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
3
in evidence of any of the material covered by this Protective Order.
4
12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
5
Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
6 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
7
the court, then the Receiving Party may file the information in the public record unless
8 otherwise instructed by the court.
9
13. FINAL DISPOSITION
10
After the final disposition of this Action, as defined in paragraph 4, within 60
11 days of a written request by the Designating Party, each Receiving Party must return
12 all Protected Material to the Producing Party or destroy such material. As used in this
subdivision, “all Protected Material” includes all copies, abstracts, compilations,
13 summaries, and any other format reproducing or capturing any of the Protected
14 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
15 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
16 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,
17 compilations, summaries or any other format reproducing or capturing any of the
18 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
19 legal memoranda, correspondence, deposition and trial exhibits, expert reports,
20 attorney work product, and consultant and expert work product, even if such materials
contain Protected Material. Any such archival copies that contain or constitute
21 Protected Material remain subject to this Protective Order as set forth in Section 4
22 (DURATION).
23 14. Any violation of this Order may be punished by any and all appropriate
measures including, without limitation, contempt proceedings and/or monetary
24
sanctions.
25
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
26
27
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1
Dated: August 14, 2023
2 /s/ Youssef Hammoud
3 Youssef Hammoud, CA #321934
E: yh@lawhammoud.com
4 HAMMOUD LAW, P.C.
5 3744 E. Chapman Ave., #F12269
Orange, CA 92859
6
T: (949) 301-9692
7 F: (949) 301-9693
Attorneys for Plaintiff
8
Adrian Zavala
9
/s/Jason A. Spak
10
Jason A. Spak [admitted pro hac vice]
11 FisherBroyles, LLP
6360 Broad Street #5262
12
Pittsburgh, PA 15206
13 T: 412-230-8555
14 E: jason.spak@fisherbroyles.com

15 David N. Makous [SBN #82409]
16 FisherBroyles, LLP
9350 Wilshire Blvd., Suite 203
17
Beverly Hills, CA 90212
18 T: 310-974-3224
E: david.makous@fisherbroyles.com
19
Counsel for Defendant,
20 FIRST ADVANTAGE BACKGROUND
SERVICES CORP.
21

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1 ATTESTATION OF SIGNATURE
9 Pursuant to Local Rule 5-4.3.4(a)(2)(i) regarding signatures, I, Youssef
3 || Hammoud, hereby attests that concurrence in the filing of this document and its
4 || content has been obtained from the other signatories.
5
6 Dated: August 14, 2023 /s/Youssef Hammoud
7
g DATED: August 16, 2023 .
9 AP abevie Lona hoe
10 Honorable Patricia Donahue
1 United States Magistrate Judge
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EXHIBIT A
1
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 United
States District Court for the Central District of California on [date] in the case of
6 __________ [insert formal name of the case and the number and initials assigned to it
7 by the court]. 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
8 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
9
Stipulated Protective Order to any person or entity except in strict compliance with the
10 provisions of this Order.
11
I further agree to submit to the jurisdiction of the United States District Court for the
12 Central District of California for the purpose of enforcing the terms of this Stipulated
Protective Order, even if such enforcement proceedings occur after termination of this
13
action. I hereby appoint ________________________ [print or type full name] of
14 _________ [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
15
enforcement of this Stipulated Protective Order.
16

17
18 Date: __________________________
19 City and State where sworn and signed: _____________________________
20
Printed name: ____________________________________
21
Signature: ________________________________
22
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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9984126. Public record. Not legal advice.