The opinion
1 Douglas C. Smith, Esq. – SBN: 160013
dsmith@smitlaw.com
2 Erin R. Brown, Esq. – SBN: 323218
ebrown@smitlaw.com
3 SMITH LAW OFFICES, LLP
4001 Eleventh Street
4 Riverside, California 92501
Telephone: (951) 509-1355
5
Attorneys for Defendants
6
Shawn A. McMillan, Esq. – SBN:208529
7 attyshawn@netscape.net
Stephen D. Daner, Esq. – SBN: 259689
8 Steve.mcmillanlaw@gmail.com
Evan D. Pullman, Esq. – SBN: 342431
9 evan.pullman.mcmillanlaw@gmail.com
THE LAW OFFICES OF SHAWN A. MCMILLAN, APC
10 4955 Via Lapiz
San Diego, California 92122
11 Telephone: (858) 646-0069
12 Attorneys for Plaintiff
13
UNITED STATES DISTRICT COURT
14 CENTRAL DISTRICT OF CALIFORNIA
15
CAROLINE VILLASANTI, ) Case No. 5:21-cv-01611-JWH-KK
16 an individual, )
) ADDITIONAL STIPULATED
17 ) PROTECTIVE ORDER
Plaintiff, )
18 ) Judge: Hon. John W. Holcomb
)
19 v. ) Courtroom: 9D
)
20 COUNTY OF RIVERSIDE, a public ) Magistrate: Hon. Kenly Kiya Kato
)
21 entity; JACQUELINE FARRIS, an ) Courtroom: 3 or 4
22 individual; JOSEPH WELSENBERGER, ) )
an individual; MARIAH LOPEZ, an
)
23 individual; JESUS CUEVAS, an )
individual; CHRISTINA PLEMONS, an )
24 )
individual; LEONOR MENDEZ, an
)
25 individual; MARCIA BUTCHER, an )
individual; and DOES 1 through 20, )
26 )
inclusive
)
27
Defendants
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 be
5 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter
6 the following Stipulated Protective Order. The parties acknowledge that this Order
7 does not confer blanket protections on all disclosures or responses to discovery and
8 that the protection it affords from public disclosure and use extends only to the
9 limited information or items that are entitled to confidential treatment under the
10 applicable legal principles. The parties further acknowledge, as set forth in Section
11 12.3, below, that this Stipulated Protective Order does not entitle them to file
12 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures
13 that must be followed and the standards that will be applied when a party seeks
14 permission from the Court to file material under seal.
15 B. GOOD CAUSE STATEMENT
16 This action will involve the exchange of confidential JUVENILE CASE FILES
17 of minor children, for which counsel for the parties obtained orders from the
18 California Juvenile Court seeking release of the JUVENILE CASE FILE. The
19 Juvenile Court issued several orders releasing JUVENILE CASE FILE records to the
20 parties and counsel for use in this matter. The JUVENILE CASE FILE records and
21 information that were ordered released to each party are relevant to this litigation and
22 should be exchanged between counsel for the parties.
23 This action will also involve the exchange of private, sensitive, and personal
24 information and records involving minor children that the Juvenile Court determined
25 are not part of the JUVENILE CASE FILE within the meaning of Cal. Welf. & Inst.
26 Code, §827 – i.e., (1) communications, emails, and/or text messages that were not
27 actually preserved and maintained in the social services practitioner's file or were
1 documented in a court report, (2) Foster Family Agency (FFA) records and
2 DOCUMENTS that are in the possession of and/or maintained by that FFA, and (3)
3 other third party records that are not actually preserved and maintained in the social
4 services practitioner's file or were documented in a court report. While these
5 DOCUMENTS are not part of the JUVENILE CASE FILE within the meaning of
6 Cal. Welf. & Inst. Code, §827, they may contain references to information and/or
7 names contained in the JUVENILE CASE FILE.
8 This Court can order the disclosure and exchange of these Juvenile Case File
9 records and/or other material specified in this Good Cause Statement. Estate of
10 Maldonado v. Sec’y of the Cal. Dep’t of Corr. & Rehab., 2007 U.S. Dist. LEXIS
11 91084, at *13-17 (E.D. Cal. Nov. 30, 2007); Doe No. 59 v. Santa Rose City Sch.,
12 2017 U.S. Dist. LEXIS 29126, at *3-5 (N.D. Cal. Mar. 1, 2017).
13 Accordingly, to expedite the flow of information, to facilitate the prompt
14 resolution of disputes over confidentiality of discovery materials, to adequately
15 protect information the parties are entitled to keep confidential, to ensure that the
16 parties are permitted reasonable necessary uses of such material in preparation for
17 and in the conduct of trial, to address their handling at the end of the litigation, and
18 serve the ends of justice, a protective order for such information is justified in this
19 matter. It is the intent of the parties that information will not be designated as
20 confidential for tactical reasons and that nothing be so designated without a good
21 faith belief that it has been maintained in a confidential, non-public manner, and there
22 is good cause why it should not be part of the public record of this case.
23 2. DEFINITIONS
24 2.1 Action: This pending federal lawsuit: Case No. 5:21-cv-01611-JWH-
25 KK.
26 2.2 Challenging Party: A Party or Non-Party that challenges the designation
27 of information or items under this Order.
1 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of
2 how it is generated, stored or maintained) or tangible things that qualify for protection
3 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
4 Cause Statement.
5 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
6 their support staff).
7 2.5 Designating Party: A Party or Non-Party that designates information or
8 items that it produces in disclosures or in responses to discovery as
9 “CONFIDENTIAL.”
10 2.6. Disclosure or Discovery Material: All items or information, regardless
11 of the medium or manner in which it is generated, stored, or maintained (including,
12 among other things, testimony, transcripts, and tangible things), that are produced or
13 generated in disclosures or responses to discovery in this matter.
14 2.7 Expert: A person with specialized knowledge or experience in a matter
15 pertinent to the litigation who has been retained by a Party or its counsel to serve as
16 an expert witness or as a consultant in this Action.
17 2.8 House Counsel: Attorneys who are employees of a party to this Action.
18 House Counsel does not include Outside Counsel of Record or any other outside
19 counsel.
20 2.9 Non-Party: Any natural person, partnership, corporation, association, or
21 other legal entity not named as a Party to this action.
22 2.10 Outside Counsel of Record: Attorneys who are not employees of a party
23 to this Action but are retained to represent or advise a party to this Action and have
24 appeared in this Action on behalf of that party or are affiliated with a law firm which
25 has appeared on behalf of that party, and includes support staff.
26
27
1 2.11 Party: Any party to this Action, including all of its officers, directors,
2 employees, consultants, retained experts, and Outside Counsel of Record (and their
3 support staffs).
4 2.12 Producing Party: A Party or Non-Party that produces Disclosure or
5 Discovery Material in this Action.
6 2.13 Professional Vendors: Persons or entities that provide litigation support
7 services (e.g., photocopying, videotaping, translating, preparing exhibits or
8 demonstrations, and organizing, storing, or retrieving data in any form or medium)
9 and their employees and subcontractors.
10 2.14 Protected Material: Any Disclosure or Discovery Material that is
11 designated as “CONFIDENTIAL.”
12 2.15 Receiving Party: A Party that receives Disclosure or Discovery Material
13 from a Producing Party.
14 2.16 Juvenile Case File: (1) All documents filed in a juvenile court case; (2)
15 Reports to the court by probation officers, social workers of child welfare services
16 programs, and CASA volunteers; (3) documents made available to probation officers,
17 social workers of child welfare services programs, and CASA volunteers in
18 preparation of reports to the court; (4) documents relating to a child concerning
19 whom a petition has been filed in juvenile court that are maintained in the office files
20 of probation officers, social workers of child welfare services programs, and CASA
21 volunteers; (5) Transcripts, records, or reports relating to matters prepared or released
22 by the court, probation department, or child welfare services program; and (6)
23 documents, video or audio tapes, photographs, and exhibits admitted into evidence at
24 juvenile court hearings. (Cal. R. Of Court, Rule 5.552(a).)
25 3. SCOPE
26 The protections conferred by this Stipulation and Order cover not only
27 Protected Material (as defined above), but also (1) any information copied or
1 extracted from Protected Material; (2) all copies, excerpts, summaries, or
2 compilations of Protected Material; and (3) any testimony, conversations, or
3 presentations by Parties or their Counsel that might reveal Protected Material.
4 Any use of Protected Material at trial shall be governed by the orders of the
5 trial judge. This Order does not govern the use of Protected Material at trial.
6 4. DURATION
7 Even after final disposition of this litigation, the confidentiality obligations
8 imposed by this Order shall remain in effect until a Designating Party agrees
9 otherwise in writing or a court order otherwise directs. Final disposition shall be
10 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
11 or without prejudice; and (2) final judgment herein after the completion and
12 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
13 including the time limits for filing any motions or applications for extension of time
14 pursuant to applicable law.
15 5. DESIGNATING PROTECTED MATERIAL
16 5.1 Exercise of Restraint and Care in Designating Material for Protection.
17 Each Party or Non-Party that designates information or items for protection under this
18 Order must take care to limit any such designation to specific material that qualifies
19 under the appropriate standards. The Designating Party must designate for protection
20 only those parts of material, documents, items, or oral or written communications that
21 qualify so that other portions of the material, documents, items, or communications
22 for which protection is not warranted are not swept unjustifiably within the ambit of
23 this Order.
24 Mass, indiscriminate, or routinized designations are prohibited. Designations
25 that are shown to be clearly unjustified or that have been made for an improper
26 purpose (e.g., to unnecessarily encumber the case development process or to impose
27
1 unnecessary expenses and burdens on other parties) may expose the Designating
2 Party to sanctions.
3 If it comes to a Designating Party’s attention that information or items that it
4 designated for protection do not qualify for protection, that Designating Party must
5 promptly notify all other Parties that it is withdrawing the inapplicable designation.
6 5.2 Manner and Timing of Designations. Except as otherwise provided in
7 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
8 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
9 under this Order must be clearly so designated before the material is disclosed or
10 produced.
11 Designation in conformity with this Order requires the following:
12 (a) For information in documentary form (e.g., paper or electronic
13 documents, but excluding transcripts of depositions or other pretrial or trial
14 proceedings), that the Producing Party affix at a minimum, the legend
15 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
16 contains protected material. If only a portion or portions of the material on a page
17 qualifies for protection, the Producing Party also must clearly identify the protected
18 portion(s) (e.g., by making appropriate markings in the margins).
19 A Party or Non-Party that makes original documents available for inspection
20 need not designate them for protection until after the inspecting Party has indicated
21 which documents it would like copied and produced. During the inspection and
22 before the designation, all of the material made available for inspection shall be
23 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
24 it wants copied and produced, the Producing Party must determine which documents,
25 or portions thereof, qualify for protection under this Order. Then, before producing
26 the specified documents, the Producing Party must affix the “CONFIDENTIAL
27 legend” to each page that contains Protected Material. If only a portion or portions of
1 the material on a page qualifies for protection, the Producing Party also must clearly
2 identify the protected portion(s) (e.g., by making appropriate markings in the
3 margins).
4 (b) For testimony given in depositions, that the Designating Party
5 identify the Disclosure or Discovery Material on the record, before the close of the
6 deposition all protected testimony.
7 (c) For information produced in form other than document and for
8 any other tangible items, that the Producing Party affix in a prominent place on the
9 exterior of the container or containers in which the information is stored the legend
10 “CONFIDENTIAL.” If only a portion or portions of the information warrants
11 protection, the Producing Party, to the extent practicable, shall identify the protected
12 portion(s).
13 5.3 Inadvertent Failure to Designate. If timely corrected, an inadvertent
14 failure to designate qualified information or items does not, standing alone, waive the
15 Designating Party’s right to secure protection under this Order for such material.
16 Upon timely correction of a designation, the Receiving Party must make reasonable
17 efforts to assure that the material is treated in accordance with the provisions of this
18 Order.
19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
20 6.1 Timing of Challenges. Any party or Non-Party may challenge a
21 designation of confidentiality at any time that is consistent with the Court’s
22 Scheduling Order.
23 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
24 resolution process under Local Rule 37.1 et seq.
25 6.3 The burden of persuasion in any such challenge proceeding shall be on
26 the Designating Party. Frivolous challenges, and those made for an improper purpose
27 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
1 expose the Challenging Party to sanctions. Unless the Designating Party has waived
2 or withdrawn the confidentiality designation, all parties shall continue to afford the
3 material in question the level of protection to which it is entitled under the Producing
4 Party’s designation until the Court rules on the challenge.
5 7. ACCESS TO AND USE OF PROTECTED MATERIAL
6 7.1 Basic Principles. A Receiving Party may use Protected Material that is
7 disclosed or produced by another Party or by a Non-Party in connection with this
8 Action only for prosecuting, defending, or attempting to settle this Action. Such
9 Protected Material may be disclosed only to the categories of persons and under the
10 conditions described in this Order. When the Action has been terminated, a
11 Receiving Party must comply with the provisions of Section 13 below (FINAL
12 DISPOSITION).
13 Protected Material must be stored and maintained by a Receiving Party at a
14 location and in a secure manner that ensures that access is limited to the persons
15 authorized under this Order.
16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
17 otherwise ordered by the Court or permitted in writing by the Designating Party, a
18 Receiving Party may disclose any information or item designated
19 “CONFIDENTIAL” only to:
20 (a) The Receiving Party’s Outside Counsel of Record in this Action,
21 as well as employees of said Outside Counsel of Record to whom it is reasonably
22 necessary to disclose the information for this Action;
23 (b) The officers, directors, and employees (including House Counsel)
24 of the Receiving Party to whom disclosure is reasonably necessary for this Action;
25 (c) Experts (as defined in this Order) of the Receiving Party to whom
26 disclosure is reasonably necessary for this Action and who have signed the
27 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
1 (d) The Court and its personnel;
2 (e) Court reporters and their staff;
3 (f) Professional jury or trial consultants, mock jurors, and
4 Professional Vendors to whom disclosure is reasonably necessary or this Action and
5 who have signed the “Acknowledgment and Agreement to be Bound” attached as
6 Exhibit A hereto;
7 (g) The author or recipient of a document containing the information
8 or a custodian or other person who otherwise possessed or knew the information;
9 (h) During their depositions, witnesses, and attorneys for witnesses, in
10 the Action to whom disclosure is reasonably necessary provided: (i) the deposing
11 party requests that the witness sign the “Acknowledgment and Agreement to Be
12 Bound;” and (ii) they will not be permitted to keep any confidential information
13 unless they sign the “Acknowledgment and Agreement to Be Bound,” unless
14 otherwise agreed by the Designating Party or ordered by the Court. Pages of
15 transcribed deposition testimony or exhibits to depositions that reveal Protected
16 Material may be separately bound by the court reporter and may not be disclosed to
17 anyone except as permitted under this Stipulated Protective Order; and
18 (i) Any mediator or settlement officer, and their supporting
19 personnel, mutually agreed upon by any of the parties engaged in settlement
20 discussions.
21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
22 OTHER LITIGATION
23 If a Party is served with a subpoena or a court order issued in other litigation
24 that compels disclosure of any information or items designated in this Action as
25 “CONFIDENTIAL,” that Party must:
26 (a) Promptly notify in writing the Designating Party. Such
27 notification shall include a copy of the subpoena or court order;
1 (b) Promptly notify in writing the party who caused the subpoena or
2 order to issue in the other litigation that some or all of the material covered by the
3 subpoena or order is subject to this Protective Order. Such notification shall include
4 a copy of this Stipulated Protective Order; and
5 (c) Cooperate with respect to all reasonable procedures sought to be
6 pursued by the Designating Party whose Protected Material may be affected.
7 If the Designating Party timely seeks a protective order, the Party served with
8 the subpoena or court order shall not produce any information designated in this
9 action as “CONFIDENTIAL” before a determination by the Court from which the
10 subpoena or order issued, unless the Party has obtained the Designating Party’s
11 permission. The Designating Party shall bear the burden and expense of seeking
12 protection in that court of its confidential material and nothing in these provisions
13 should be construed as authorizing or encouraging a Receiving Party in this Action to
14 disobey a lawful directive from another court.
15 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
16 PRODUCED IN THIS LITIGATION
17 (a) The terms of this Order are applicable to information produced by a
18 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
19 produced by Non-Parties in connection with this litigation is protected by the
20 remedies and relief provided by this Order. Nothing in these provisions should be
21 construed as prohibiting a Non-Party from seeking additional protections.
22 (b) In the event that a Party is required, by a valid discovery request, to
23 produce a Non-Party’s confidential information in its possession, and the Party is
24 subject to an agreement with the Non-Party not to produce the Non-Party’s
25 confidential information, then the Party shall:
26
27
1 (1) Promptly notify in writing the Requesting Party and the Non Party
2 that some or all of the information requested is subject to a confidentiality agreement
3 with a Non-Party;
4 (2) Promptly provide the Non-Party with a copy of the Stipulated
5 Protective Order in this Action, the relevant discovery request(s), and a reasonably
6 specific description of the information requested; and
7 (3) Make the information requested available for inspection by the
8 Non-Party, if requested.
9 (c) If the Non-Party fails to seek a protective order from this court within 14
10 days of receiving the notice and accompanying information, the Receiving Party may
11 produce the Non-Party’s confidential information responsive to the discovery request.
12 If the Non-Party timely seeks a protective order, the Receiving Party shall not
13 produce any information in its possession or control that is subject to the
14 confidentiality agreement with the Non-Party before a determination by the court.
15 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
16 of seeking protection in this court of its Protected Material.
17 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
18 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
19 Protected Material to any person or in any circumstance not authorized under this
20 Stipulated Protective Order, the Receiving Party must immediately (1) notify in
21 writing the Designating Party of the unauthorized disclosures, (2) use its best efforts
22 to retrieve all unauthorized copies of the Protected Material, (3) inform the person or
23 persons to whom unauthorized disclosures were made of all the terms of this Order,
24 and (4) request such person or persons to execute the “Acknowledgment and
25 Agreement to be Bound” that is attached hereto as Exhibit A.
26 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
27 PROTECTED MATERIAL
1 When a Producing Party gives notice to Receiving Parties that certain
2 inadvertently produced material is subject to a claim of privilege or other protection,
3 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
4 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
5 may be established in an e-discovery order that provides for production without prior
6 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
7 parties reach an agreement on the effect of disclosure of a communication or
8 information covered by the attorney-client privilege or work product protection, the
9 parties may incorporate their agreement in the Stipulated Protective Order submitted
10 to the Court.
11 12. MISCELLANEOUS
12 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
13 person to seek its modification by the Court in the future.
14 12.2 Right to Assert Other Objections. By stipulating to the entry of this
15 Protective Order, no Party waives any right it otherwise would have to object to
16 disclosing or producing any information or item on any ground not addressed in this
17 Stipulated Protective Order. Similarly, no Party waives any right to object on any
18 ground to use in evidence of any of the material covered by this Protective Order.
19 12.3 Filing Protected Material. A Party that seeks to file under seal any
20 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
21 only be filed under seal pursuant to a court order authorizing the sealing of the
22 specific Protected Material at issue. If a Party's request to file Protected Material
23 under seal is denied by the Court, then the Receiving Party may file the information
24 in the public record unless otherwise instructed by the Court.
25 13. FINAL DISPOSITION
26 After the final disposition of this Action, as defined in Section 4, within sixty
27 (60) days of a written request by the Designating Party, each Receiving Party must
1 return all Protected Material to the Producing Party or destroy such material. As used
2 in this subdivision, “all Protected Material” includes all copies, abstracts,
3 compilations, summaries, and any other format reproducing or capturing any of the
4 Protected Material. Whether the Protected Material is returned or destroyed, the
5 Receiving Party must submit a written certification to the Producing Party (and, if not
6 the same person or entity, to the Designating Party) by the 60 day deadline that (1)
7 identifies (by category, where appropriate) all the Protected Material that was
8 returned or destroyed and (2) affirms that the Receiving Party has not retained any
9 copies, abstracts, compilations, summaries or any other format reproducing or
10 capturing any of the Protected Material.
11 Notwithstanding this provision, Counsel are entitled to retain an archival copy
12 of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
13 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
14 work product, and consultant and expert work product, even if such materials contain
15 Protected Material. Any such archival copies that contain or constitute Protected
16 Material remain subject to this Protective Order as set forth in Section 4
17 (DURATION).
18 Further, Plaintiffs may retain any CONFIDENTIAL MATERIAL, such as their
19 client’s juvenile case file records and/or medical records that he or she would
20 otherwise be legally entitled to retain. Finally, attorney work product that contains
21 CONFIDENTIAL MATERIAL need not be destroyed, but, if it is not destroyed, the
22 person in possession of the attorney work product will continue to be bound by this
23 Order with respect to all such retained MATERIAL, after the conclusion of this
24 litigation.
25 This Order may be modified by agreement of the parties, subject to approval by
26 the Court.
27
1114. Any violation of this Order may be punished by any and all appropriate
2 || measures including, without limitation, contempt proceedings and/or monetary
3 || sanctions.
4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
5
6
Dated: 9/5/2023 /s/ Stephen Daner
7 Shawn A. McMillan, Esq.
8 Stephen D. Daner, Esq.
Attorneys for Plaintiffs
9
10
11
12 || Dated:__9/5/2023 ___/s/ Erin Brown
Doug C. Smith, Esq.
13 Erin R. Brown, Esq.
14 Attorneys for Defendants
15 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
16
17
1g || Dated: 9/5/2023 Lew
U.S. Magistrate Judge Kenly Kiya Kato
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-15-
1 EXHIBIT A
2
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4
I, [print or type full name], of
5
[print or type full address], declare under penalty of perjury that I have
6
read in its entirety and understand the Stipulated Protective Order that was issued by
7
the United States District Court for the Central District of California on [DATE] in
8
the case of K.W.1 v. County of Riverside, Case No. 5:21-cv-01216-JWH-SHK. I
9
agree to comply with and to be bound by all the terms of this Stipulated Protective
10
Order and I understand and acknowledge that failure to so comply could expose me
11
to sanctions and punishment in the nature of contempt. I solemnly promise that I will
12
not disclose in any manner any information or item that is subject to this Stipulated
13
Protective Order to any person or entity except in strict compliance with the
14
provisions of this Order.
15
I further agree to submit to the jurisdiction of the United States District Court
16
for the Central District of California for the purpose of enforcing the terms of this
17
Stipulated Protective Order, even if such enforcement proceedings occur after
18
termination of this action. I hereby appoint [print or type
19
full name] of [print or type full address and telephone
20
number] as my California agent for service of process in connection with this action
21
or any proceedings related to enforcement of this Stipulated Protective Order.
22
Date:
23
City and State where sworn and signed:
24
Printed Name:
25
Signature:
26
27