# Gabriela Koutantos v. County of Los Angeles

> District Court, C.D. California · February 28, 2024

URL: https://www.frixlaw.com/law-library/cases/9985997

## Case

- **Court:** District Court, C.D. California
- **Decided:** February 28, 2024
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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12 UNITED STATES DISTRICT COURT

13 CENTRAL DISTRICT OF CALIFORNIA

14 GABRIELA KOUTANTOS and Case No.: 2:23-cv-08592-HDV (RAOx)
BARBARA KAPPOS,
15 [Assigned to the Honorable Hernán D.
Vera - Department 5B]
16 Plaintiff,

17 v. STIPULATED PROTECTIVE ORDER1

18 COUNTY OF LOS ANGELES; and
DOES 1- 10. Complaint Filed: October 12, 2023
19 Discovery Cut-Off: Not Set
Defendants. Motion Cut-Off: Not Set
20 Trial: Not Set
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27
1 This Stipulated Protective Order is substantially based on the model protective order
28 provided under Magistrate Judge Rozella A. Oliver’s Procedures.
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 disclosure
4 and from use for any purpose other than prosecuting this litigation may be warranted.
5 Accordingly, the parties hereby stipulate to and petition the Court to enter the following
6 Stipulated Protective Order. The parties acknowledge that this Order does not confer
7 blanket protections on all disclosures or responses to discovery and that the protection it
8 affords from public disclosure and use extends only to the limited information or items
9 that are entitled to confidential treatment under the applicable legal principles.
10 B. GOOD CAUSE STATEMENT
11 1. This action involves the County of Los Angeles and members of the Los
12 Angeles County Sheriff’s Department. Plaintiffs intend to seek materials and
13 information that Defendant contends are confidential, such as personnel files of the
14 deputies involved in the incident. Defendant contends that this action is likely to
15 involve confidential, proprietary, official, and/or private law enforcement and police
16 personnel information for which special protection from public disclosure and from use
17 for any purpose other than prosecution of this action is warranted. Defendant contends
18 that such confidential and proprietary materials and information consist of, among other
19 things, confidential proprietary information/or private personnel police information,
20 regarding confidential contained in police personnel files, official law enforcement
21 investigative information, information otherwise generally unavailable to the public, or
22 which may be privileged or otherwise protected from disclosure under state or federal
23 statutes, court rules, case decisions, or common law.
24 Defendant may seek information such as Plaintiffs’ medical records that
25 Plaintiffs believe are highly sensitive, confidential, and are legally protected from
26 disclosure. See Wooden v. Comprehensive Health Mgmt., No. 20-00053 LEK-WRP,
27 2021 U.S. Dist. LEXIS 101889, at *3 (D. Haw. May 28, 2021) (“[M]edical records are
28 confidential, as recognized under the Health Insurance Portability and Accountability
1 Act of 1996.”); Pratt v. Gamboa, No. 17-CV-04375-LHK, 2020 U.S. Dist. LEXIS
2 90913, at *5 (N.D. Cal. May 22, 2020) (same). Plaintiffs contend that the undue
3 disclosure of such information creates a specific risk of embarrassment, emotional
4 harm, reputational harm, and professional harm.
5 Accordingly, to expedite the flow of information, to facilitate the prompt
6 resolution of disputes over confidentiality of discovery materials, to adequately protect
7 information the parties are entitled to keep confidential, to ensure that the parties are
8 permitted reasonable necessary uses of such material in preparation for and in the
9 conduct of trial, to address their handling at the end of the litigation, and serve the ends
10 of justice, a protective order for such information is justified in this matter. It is the
11 intent of the parties that information will not be designated as confidential for tactical
12 reasons and that nothing be so designated without a good faith belief that it has been
13 maintained in a confidential, non-public manner, and there is good cause why it should
14 not be part of the public record of this case.
15 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
16 The parties further acknowledge, as set forth in Section 12.3, below, that this
17 Stipulated Protective Order does not entitle them to file confidential information under
18 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
19 standards that will be applied when a party seeks permission from the court to file
20 material under seal.
21 There is a strong presumption that the public has a right of access to judicial
22 proceedings and records in civil cases. In connection with non-dispositive motions,
23 good cause must be shown to support a filing under seal. See Kamakana v. City and
24 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
25 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, Inc.,
26 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good
27 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 of
2 Disclosure or Discovery Material as CONFIDENTIAL does not—without the
3 submission of competent evidence by declaration, establishing that the material sought
4 to be filed under seal qualifies as confidential, privileged, or otherwise protectable—
5 constitute good cause.
6 Further, if a party requests sealing related to a dispositive motion or trial, then
7 compelling reasons, not only good cause, for the sealing must be shown, and the relief
8 sought shall be narrowly tailored to serve the specific interest to be protected. See
9 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
10 or type of information, document, or thing sought to be filed or introduced under seal in
11 connection with a dispositive motion or trial, the party seeking protection must
12 articulate compelling reasons, supported by specific facts and legal justification, for the
13 requested sealing order. Again, competent evidence supporting the application to file
14 documents under seal must be provided by declaration.
15 Any document that is not confidential, privileged, or otherwise protectable in its
16 entirety will not be filed under seal if the confidential portions can be redacted. If
17 documents can be redacted, then a redacted version for public viewing, omitting only
18 the confidential, privileged, or otherwise protectable portions of the document shall be
19 filed. Any application that seeks to file documents under seal in their entirety should
20 include an explanation of why redaction is not feasible.
21
22 2. DEFINITIONS
23 2.1 Action: Koutantos v. County of Los Angeles, 2:23-cv-08592-HDV (RAOx)
24 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
25 information or items under this Order.
26 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
27 it is generated, stored or maintained) or tangible things that qualify for protection under
28 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
1 Statement.
2 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
3 support staff).
4 2.5 Designating Party: a Party or Non-Party that designates information or
5 items that it produces in disclosures or in responses to discovery as
6 “CONFIDENTIAL.”
7 2.6 Disclosure or Discovery Material: all items or information, regardless of
8 the medium or manner in which it is generated, stored, or maintained (including, among
9 other things, testimony, transcripts, and tangible things) that are produced or generated
10 in disclosures or responses to discovery in this matter.
11 2.7 Expert: a person with specialized knowledge or experience in a matter
12 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
13 expert witness or as a consultant in this Action.
14 2.8 House Counsel: attorneys who are employees of a party to this Action.
15 House Counsel does not include Outside Counsel of Record or any other outside
16 counsel.
17 2.9 Non-Party: any natural person, partnership, corporation, association or
18 other legal entity not named as a Party to this action.
19 2.10 Outside Counsel of Record: attorneys who are not employees of a party to
20 this Action but are retained to represent or advise a party to this Action and have
21 appeared in this Action on behalf of that party or are affiliated with a law firm that has
22 appeared on behalf of that party, and includes support staff.
23 2.11 Party: any party to this Action, including all of its officers, directors,
24 employees, consultants, retained experts, and Outside Counsel of Record (and their
25 support staffs).
26 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
27 Discovery Material in this Action.
28 2.13 Professional Vendors: persons or entities that provide litigation support
1 services (e.g., photocopying, videotaping, translating, preparing exhibits or
2 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
3 their employees and subcontractors.
4 2.14 Protected Material: any Disclosure or Discovery Material that is
5 designated as “CONFIDENTIAL.”
6 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
7 from a Producing Party.
8
9 3. SCOPE
10 The protections conferred by this Stipulation and Order cover not only Protected
11 Material (as defined above), but also (1) any information copied or extracted from
12 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
13 Material; and (3) any testimony, conversations, or presentations by Parties or their
14 Counsel that might reveal Protected Material.
15 Any use of Protected Material at trial shall be governed by the orders of the trial
16 judge. This Order does not govern the use of Protected Material at trial.
17
18 4. DURATION
19 Once a case proceeds to trial, information that was designated as
20 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as
21 an exhibit at trial becomes public and will be presumptively available to all members of
22 the public, including the press, unless compelling reasons supported by specific factual
23 findings to proceed otherwise are made to the trial judge in advance of the trial. See
24 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing
25 documents produced in discovery from “compelling reasons” standard when merits-
26 related documents are part of court record). Accordingly, the terms of this protective
27 order do not extend beyond the commencement of the trial.
28
1 5. DESIGNATING PROTECTED MATERIAL
2 5.1 Exercise of Restraint and Care in Designating Material for Protection.
3 Each Party or Non-Party that designates information or items for protection under this
4 Order must take care to limit any such designation to specific material that qualifies
5 under the appropriate standards. The Designating Party must designate for protection
6 only those parts of material, documents, items or oral or written communications that
7 qualify so that other portions of the material, documents, items or communications for
8 which protection is not warranted are not swept unjustifiably within the ambit of this
9 Order.
10 Mass, indiscriminate or routinized designations are prohibited. Designations that
11 are shown to be clearly unjustified or that have been made for an improper purpose
12 (e.g., to unnecessarily encumber the case development process or to impose
13 unnecessary expenses and burdens on other parties) may expose the Designating Party
14 to sanctions.
15 If it comes to a Designating Party’s attention that information or items that it
16 designated for protection do not qualify for protection, that Designating Party must
17 promptly notify all other Parties that it is withdrawing the inapplicable designation.
18 5.2 Manner and Timing of Designations. Except as otherwise provided in this
19 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
20 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
21 must be clearly so designated before the material is disclosed or produced.
22 Designation in conformity with this Order requires:
23 (a) for information in documentary form (e.g., paper or electronic documents,
24 but excluding transcripts of depositions or other pretrial or trial proceedings), that the
25 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
26 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
27 portion of the material on a page qualifies for protection, the Producing Party also must
28 clearly identify the protected portion(s) (e.g., by making appropriate markings in the
1 margins).
2 A Party or Non-Party that makes original documents available for inspection
3 need not designate them for protection until after the inspecting Party has indicated
4 which documents it would like copied and produced. During the inspection and before
5 the designation, all of the material made available for inspection shall be deemed
6 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
7 copied and produced, the Producing Party must determine which documents, or portions
8 thereof, qualify for protection under this Order. Then, before producing the specified
9 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
10 that contains Protected Material. If only a portion of the material on a page qualifies for
11 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,
12 by making appropriate markings in the margins).
13 (b) for testimony given in depositions that the Designating Party identifies the
14 Disclosure or Discovery Material on the record, before the close of the deposition all
15 protected testimony.
16 (c) for information produced in some form other than documentary and for
17 any other tangible items, that the Producing Party affix in a prominent place on the
18 exterior of the container or containers in which the information is stored the legend
19 “CONFIDENTIAL.” If only a portion or portions of the information warrants
20 protection, the Producing Party, to the extent practicable, shall identify the protected
21 portion(s).
22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
23 failure to designate qualified information or items does not, standing alone, waive the
24 Designating Party’s right to secure protection under this Order for such material. Upon
25 timely correction of a designation, the Receiving Party must make reasonable efforts to
26 assure that the material is treated in accordance with the provisions of this Order.
27
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1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
3 designation of confidentiality at any time that is consistent with the Court’s Scheduling
4 Order.
5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
6 resolution process under Local Rule 37.1 et seq.
7 6.3 The burden of persuasion in any such challenge proceeding shall be on the
8 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
9 to harass or impose unnecessary expenses and burdens on other parties) may expose the
10 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
11 the confidentiality designation, all parties shall continue to afford the material in
12 question the level of protection to which it is entitled under the Producing Party’s
13 designation until the Court rules on the challenge.
14
15 7. ACCESS TO AND USE OF PROTECTED MATERIAL
16 7.1 Basic Principles. A Receiving Party may use Protected Material that is
17 disclosed or produced by another Party or by a Non-Party in connection with this
18 Action only for prosecuting, defending or attempting to settle this Action. Such
19 Protected Material may be disclosed only to the categories of persons and under the
20 conditions described in this Order. When the Action has been terminated, a Receiving
21 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
22 Protected Material must be stored and maintained by a Receiving Party at a
23 location and in a secure manner that ensures that access is limited to the persons
24 authorized 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
27 may disclose any information or item designated “CONFIDENTIAL” only to:
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
6 disclosure is reasonably necessary for this Action and who have signed the
7 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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
11 Vendors to whom disclosure is reasonably necessary for this Action and who have
12 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
13 (g) the author or recipient of a document containing the information or a
14 custodian or other person who otherwise possessed or knew the information;
15 (h) during their depositions, witnesses, and attorneys for witnesses, in the
16 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
17 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
18 not be permitted to keep any confidential information unless they sign the
19 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
20 by the Designating Party or ordered by the court. Pages of transcribed deposition
21 testimony or exhibits to depositions that reveal Protected Material may be separately
22 bound by the court reporter and may not be disclosed to anyone except as permitted
23 under this Stipulated Protective Order; and
24 (i) any mediator or settlement officer, and their supporting personnel,
25 mutually agreed upon by any of the parties engaged in settlement discussions.
26 / / /
27 / / /
28 / / /
1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
2 IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation that
4 compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL,” that Party must:
6 (a) promptly notify in writing the Designating Party. Such notification shall
7 include a copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or order to
9 issue in the other litigation that some or all of the material covered by the subpoena or
10 order is subject to this Protective Order. Such notification shall include a copy of this
11 Stipulated Protective Order; and
12 (c) cooperate with respect to all reasonable procedures sought to be pursued
13 by the Designating Party whose Protected Material may be affected.
14 If the Designating Party timely seeks a protective order, the Party served with the
15 subpoena or court order shall not produce any information designated in this action as
16 “CONFIDENTIAL” before a determination by the court from which the subpoena or
17 order issued, unless the Party has obtained the Designating Party’s permission. The
18 Designating Party shall bear the burden and expense of seeking protection in that court
19 of its confidential material and nothing in these provisions should be construed as
20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
21 directive from another court.
22
23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
24 IN THIS LITIGATION
25 (a) The terms of this Order are applicable to information produced by a Non-
26 Party in this Action and designated as “CONFIDENTIAL.” Such information produced
27 by Non-Parties in connection with this litigation is protected by the remedies and relief
28 provided by this Order. Nothing in these provisions should be construed as prohibiting
1 a Non-Party from seeking additional protections.
2 (b) In the event that a Party is required, by a valid discovery request, to
3 produce a Non-Party’s confidential information in its possession, and the Party is
4 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential
5 information, then the Party shall:
6 (1) promptly notify in writing the Requesting Party and the Non-Party that
7 some or all of the information requested is subject to a confidentiality agreement with a
8 Non-Party;
9 (2) promptly provide the Non-Party with a copy of the Stipulated
10 Protective Order in this Action, the relevant discovery request(s), and a reasonably
11 specific description of the information requested; and
12 (3) make the information requested available for inspection by the Non-
13 Party, if requested.
14 (c) If the Non-Party fails to seek a protective order from this court within 14
15 days of receiving the notice and accompanying information, the Receiving Party may
16 produce the Non-Party’s confidential information responsive to the discovery request.
17 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
18 any information in its possession or control that is subject to the confidentiality
19 agreement with the Non-Party before a determination by the court. Absent a court order
20 to the contrary, the Non-Party shall bear the burden and expense of seeking protection
21 in this court of its Protected Material.
22
23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
25 Protected Material to any person or in any circumstance not authorized under this
26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
27 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
28 all unauthorized copies of the Protected Material, (c) inform the person or persons to
1 whom unauthorized disclosures were made of all the terms of this Order, and (d)
2 request such person or persons to execute the “Acknowledgment and Agreement to Be
3 Bound” that is attached hereto as Exhibit A.
4
5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
6 PROTECTED MATERIAL
7 When a Producing Party gives notice to Receiving Parties that certain
8 inadvertently produced material is subject to a claim of privilege or other protection, the
9 obligations of the Receiving Parties are those set forth in Federal Rule of Civil
10 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
11 may be established in an e-discovery order that provides for production without prior
12 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
13 parties reach an agreement on the effect of disclosure of a communication or
14 information covered by the attorney-client privilege or work product protection, the
15 parties may incorporate their agreement in the stipulated protective order submitted to
16 the court.
17
18 12. MISCELLANEOUS
19 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
20 person to seek its modification by the Court in the future.
21 12.2 Right to Assert Other Objections. By stipulating to the entry of this
22 Protective Order, no Party waives any right it otherwise would have to object to
23 disclosing or producing any information or item on any ground not addressed in this
24 Stipulated Protective Order. Similarly, no Party waives any right to object on any
25 ground to use in evidence of any of the material covered by this Protective Order.
26 12.3 Filing Protected Material. A Party that seeks to file under seal any
27 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
28 only be filed under seal pursuant to a court order authorizing the sealing of the specific
1 Protected Material at issue. If a Party’s request to file Protected Material under seal is
2 denied by the court, then the Receiving Party may file the information in the public
3 record unless otherwise instructed by the court.
4
5 13. FINAL DISPOSITION
6 After the final disposition of this Action, as defined in paragraph 4, within 60
7 days of a written request by the Designating Party, each Receiving Party must return all
8 Protected Material to the Producing Party or destroy such material. As used in this
9 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
10 summaries, and any other format reproducing or capturing any of the Protected
11 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
12 must submit a written certification to the Producing Party (and, if not the same person
13 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
14 category, where appropriate) all the Protected Material that was returned or destroyed
15 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
16 compilations, summaries or any other format reproducing or capturing any of the
17 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
18 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
19 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
20 work product, and consultant and expert work product, even if such materials contain
21 Protected Material. Any such archival copies that contain or constitute Protected
22 Material remain subject to this Protective Order as set forth in Section 4 (DURATION).
23 / / /
24 / / /
25 / / /
26 / / /
27 / / /
28 / / /
1 | 14. VIOLATION
2 Any violation of this Order may be punished by appropriate measures including,
3 | without limitation, contempt proceedings and/or monetary sanctions.
4
5 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6
7 | DATED: 2/28/2024
8
9 /s/ Brian Olney
10 | Attorneys for Plaintiffs
11
12
13 | DATED: 2/28/2024
14
15 /s/ Janet Keuper
16 | Attorneys for Defendant
17
18
19 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
20
21 | DATED: 2/28/2024
22 .
»| Rapehis, a.
24 | HON. ROZELLA A. OLIVER
25 | United States Magistrate Judge
26
27
28
JOINT RIT E26/M REPORT..~— -|4-

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 read in its
6 entirety and understand the Stipulated Protective Order that was issued by the United
7 States District Court for the Central District of California on [date] in the case of
8 Gabriela Koutantos, et al. v County of Los Angeles, et al.; Case No.: 2:23-cv-08592-
9 HDV (RAOx). I agree to comply with and to be bound by all the terms of this
10 Stipulated Protective Order and I understand and acknowledge that failure to so comply
11 could expose me to sanctions and punishment in the nature of contempt. I solemnly
12 promise that I will not disclose in any manner any information or item that is subject to
13 this Stipulated Protective Order to any person or entity except in strict compliance with
14 the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court for the
16 Central District of California for enforcing the terms of this Stipulated Protective Order,
17 even if such enforcement proceedings occur after termination of this action. I hereby
18 appoint __________________________ [print or type full name] of
19 _______________________________________ [print or type full address and
20 telephone number] as my California agent for service of process in connection with this
21 action or any proceedings related to enforcement of this Stipulated Protective Order.
22 Date: ______________________________________
23 City and State where sworn and signed: _________________________________
24
25 Printed name: _______________________________
26
27 Signature: __________________________________
28

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9985997. Public record. Not legal advice.