1
UNITED STATES DISTRICT COURT
2
CENTRAL DISTRICT OF CALIFORNIA
3
4
Case No.
5 Plaintiff(s),
6 v.
STIPULATED PROTECTIVE
7 ORDER1
8 Defendant(s).
9
10
11 1. INTRODUCTION
12 1.1 Purposes and Limitations. Discovery in this action is likely to
13
involve production of confidential, proprietary, or private information for
14
which special protection from public disclosure and from use for any
15
purpose other than prosecuting this litigation may be warranted.
16
Accordingly, the parties hereby stipulate to and petition the court to
17
enter the following Stipulated Protective Order. The parties
18
acknowledge that this Order does not confer blanket protections on all
19
disclosures or responses to discovery and that the protection it affords
20
from public disclosure and use extends only to the limited information or
21
items that are entitled to confidential treatment under the applicable
22
legal principles.
23
24
25
26
27
1This Stipulated Protective Order is substantially based on the model
protective order provided under Magistrate Judge Stephanie S.
28 Christensen’s Procedures as of 24 July 2023.
1 1.2 Good Cause Statement. [*The “Good Cause Statement”
2 should be edited to include or exclude specific information that
3 applies to the particular case, i.e., what harm will result from the
4 disclosure of the confidential information likely to be produced
5 in this case? Below is an example]:
6 This action is likely to involve trade secrets, customer and pricing
7 lists and other valuable research, development, commercial, financial,
8
technical and/or proprietary information for which special protection
9
from public disclosure and from use for any purpose other than
10
prosecution of this action is warranted. Such confidential and
11
proprietary materials and information consist of, among other things,
12
confidential business or financial information, information regarding
13
confidential business practices, or other confidential research,
14
development, or commercial information (including information
15
implicating privacy rights of third parties), information otherwise
16
generally unavailable to the public, or which may be privileged or
17
otherwise protected from disclosure under state or federal statutes, court
18
19
rules, case decisions, or common law. Accordingly, to expedite the flow of
20 information, to facilitate the prompt resolution of disputes over
21 confidentiality of discovery materials, to adequately protect information
22 the parties are entitled to keep confidential, to ensure that the parties
23 are permitted reasonable necessary uses of such material in preparation
24 for and in the conduct of trial, to address their handling at the end of the
25 litigation, and serve the ends of justice, a protective order for such
26 information is justified in this matter. It is the intent of the parties that
27 information will not be designated as confidential for tactical reasons
28 and that nothing be so designated without a good faith belief that it has
2
1 been maintained in a confidential, non-public manner, and there is good
2 cause why it should not be part of the public record of this case.
3 1.3 Acknowledgment of Procedure for Filing Under Seal. The
4 parties further acknowledge, as set forth in Section 12.3, below, that this
5 Stipulated Protective Order does not entitle them to file confidential
6 information under seal; Local Rule 79-5 sets forth the procedures that
7 must be followed and the standards that will be applied when a party
8
seeks permission from the court to file material under seal.
9
There is a strong presumption that the public has a right of access
10
to judicial proceedings and records in civil cases. In connection with
11
non-dispositive motions, good cause must be shown to support a filing
12
under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d
13
1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors
14
Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony
15
Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
16
protective orders require good cause showing), and a specific showing of
17
good cause or compelling reasons with proper evidentiary support and
18
19
legal justification, must be made with respect to Protected Material that
20 a party seeks to file under seal. The parties’ mere designation of
21 Disclosure or Discovery Material as CONFIDENTIAL does not—
22 without the submission of competent evidence by declaration,
23 establishing that the material sought to be filed under seal qualifies as
24 confidential, privileged, or otherwise protectable—constitute good cause.
25 Further, if a party requests sealing related to a dispositive motion
26 or trial, then compelling reasons, not only good cause, for the sealing
27 must be shown, and the relief sought shall be narrowly tailored to serve
28 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,
3
1 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of
2 information, document, or thing sought to be filed or introduced under
3 seal in connection with a dispositive motion or trial, the party seeking
4 protection must articulate compelling reasons, supported by specific
5 facts and legal justification, for the requested sealing order. Again,
6 competent evidence supporting the application to file documents under
7 seal must be provided by declaration.
8
Any document that is not confidential, privileged, or otherwise
9
protectable in its entirety will not be filed under seal if the confidential
10
portions can be redacted. If documents can be redacted, then a redacted
11
version for public viewing, omitting only the confidential, privileged, or
12
otherwise protectable portions of the document, shall be filed. Any
13
application that seeks to file documents under seal in their entirety
14
should include an explanation of why redaction is not feasible.
15
16
2. DEFINITIONS
17
18 2.1 Action: [this pending federal lawsuit]. [*Option: consolidated
19 or related actions.]
20 2.2 Challenging Party: a Party or Non-Party that challenges the
21 designation of information or items under this Order.
22 2.3 “CONFIDENTIAL” Information or Items: information
23 (regardless of how it is generated, stored or maintained) or tangible
24 things that qualify for protection under Rule 26(c) of the Federal Rules of
25 Civil Procedure, and as specified above in the Good Cause Statement.
26
2.4 Counsel: Outside Counsel of Record and House Counsel (as
27
well as their support staff).
28
4
1 2.5 Designating Party: a Party or Non-Party that designates
2 information or items that it produces in disclosures or in responses to
3 discovery as “CONFIDENTIAL.”
4 2.6 Disclosure or Discovery Material: all items or information,
5 regardless of the medium or manner in which it is generated, stored, or
6 maintained (including, among other things, testimony, transcripts, and
7 tangible things), that are produced or generated in disclosures or
8
responses to discovery in this matter.
9
2.7 Expert: a person with specialized knowledge or experience in
10
a matter pertinent to the litigation who has been retained by a Party or
11
its counsel to serve as an expert witness or as a consultant in this Action.
12
2.8 Final Disposition: the later of (1) dismissal of all claims and
13
defenses in this Action, with or without prejudice; and (2) final judgment
14
herein after the completion and exhaustion of all appeals, rehearings,
15
remands, trials, or reviews of this Action, including the time limits for
16
filing any motions or applications for extension of time pursuant to
17
applicable law.
18
19 2.9 In-House Counsel: attorneys who are employees of a party to
20 this Action. In-House Counsel does not include Outside Counsel of
21 Record or any other outside counsel.
22 2.10 Non-Party: any natural person, partnership, corporation,
23 association, or other legal entity not named as a Party to this action.
24 2.11 Outside Counsel of Record: attorneys who are not employees
25 of a party to this Action but are retained to represent or advise a party to
26 this Action and have appeared in this Action on behalf of that party or
27 are affiliated with a law firm which has appeared on behalf of that party,
28 and includes support staff.
5
1 2.12 Party: any party to this Action, including all of its officers,
2 directors, employees, consultants, retained experts, and Outside Counsel
3 of Record (and their support staffs).
4 2.13 Producing Party: a Party or Non-Party that produces
5 Disclosure or Discovery Material in this Action.
6 2.14 Professional Vendors: persons or entities that provide
7 litigation- support services (e.g., photocopying, videotaping, translating,
8
preparing exhibits or demonstrations, and organizing, storing, or
9
retrieving data in any form or medium) and their employees and
10
subcontractors.
11
2.15 Protected Material: any Disclosure or Discovery Material that
12
is designated as “CONFIDENTIAL.”
13
2.16 Receiving Party: a Party that receives Disclosure or Discovery
14
Material from a Producing Party.
15
16
3. SCOPE
17
18 The protections conferred by this Stipulation and Order cover not
19 only Protected Material (as defined above), but also (1) any information
20 copied or extracted from Protected Material; (2) all copies, excerpts,
21 summaries, or compilations of Protected Material; and (3) any
22 testimony, conversations, or presentations by Parties or their Counsel
23 that might reveal Protected Material.
24 Any use of Protected Material at trial shall be governed by the
25 orders of the trial judge. This Stipulated Protective Order does not
26
govern the use of Protected Material at trial.
27
28
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1 4. TRIAL AND DURATION
2 The terms of this Stipulated Protective Order apply through Final
3 Disposition of the Action.
4
Once a case proceeds to trial, information that was designated as
5
CONFIDENTIAL or maintained pursuant to this Stipulated Protective
6
Order and used or introduced as an exhibit at trial becomes public and
7
will be presumptively available to all members of the public, including
8
the press, unless compelling reasons supported by specific factual
9
findings to proceed otherwise are made to the trial judge in advance of
10
11 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good
12 cause” showing for sealing documents produced in discovery from
13 “compelling reasons” standard when merits-related documents are part
14 of court record). Accordingly, for such materials, the terms of this
15 Stipulated Protective Order do not extend beyond the commencement of
16 the trial.
17 [Optional addition:]
18 Even after Final Disposition of this litigation, the confidentiality
19 obligations imposed by this Stipulated Protective Order shall remain in
20 effect until a Designating Party agrees otherwise in writing or a court
21 order otherwise directs.
22
23
5. DESIGNATING PROTECTED MATERIAL
24
5.1 Exercise of Restraint and Care in Designating Material for
25
Protection. Each Party or Non-Party that designates information or
26
items for protection under this Order must take care to limit any such
27
designation to specific material that qualifies under the appropriate
28
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1 standards. The Designating Party must designate for protection only
2 those parts of material, documents, items, or oral or written
3 communications that qualify so that other portions of the material,
4 documents, items, or communications for which protection is not
5 warranted are not swept unjustifiably within the ambit of this Order.
6 Mass, indiscriminate, or routinized designations are prohibited.
7 Designations that are shown to be clearly unjustified or that have been
8
made for an improper purpose (e.g., to unnecessarily encumber the case
9
development process or to impose unnecessary expenses and burdens on
10
other parties) may expose the Designating Party to sanctions.
11
If it comes to a Designating Party’s attention that information or
12
items that it designated for protection do not qualify for protection, that
13
Designating Party must promptly notify all other Parties that it is
14
withdrawing the inapplicable designation.
15
16 5.2 Manner and Timing of Designations. Except as otherwise
17 provided in this Stipulated Protective Order (see, e.g., second paragraph
18 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
19 or Discovery Material that qualifies for protection under this Stipulated
20 Protective Order must be clearly so designated before the material is
21 disclosed or produced.
22 Designation in conformity with this Stipulated Protective Order
23 requires:
24 (a) for information in documentary form (e.g., paper or electronic
25 documents, but excluding transcripts of depositions or other pretrial or
26
trial proceedings), that the Producing Party affix at a minimum, the
27
legend “CONFIDENTIAL” to each page that contains protected
28
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1 material. If only a portion or portions of the material on a page
2 qualifies for protection, the Producing Party also must clearly identify
3 the protected portion(s) (e.g., by making appropriate markings in the
4 margins).
5 A Party or Non-Party that makes original documents available for
6 inspection need not designate them for protection until after the
7 inspecting Party has indicated which documents it would like copied
8
and produced. During the inspection and before the designation, all of
9
the material made available for inspection shall be deemed
10
CONFIDENTIAL. After the inspecting Party has identified the
11
documents it wants copied and produced, the Producing Party must
12
determine which documents, or portions thereof, qualify for protection
13
under this Stipulated Protective Order. Then, before producing the
14
specified documents, the Producing Party must affix the
15
“CONFIDENTIAL” legend to each page that contains Protected
16
Material. If only a portion or portions of the material on a page
17
qualifies for protection, the Producing Party also must clearly identify
18
19
the protected portion(s) (e.g., by making appropriate markings in the
20 margins).
21 (b) for testimony given in depositions that the Designating Party
22 identify the Disclosure or Discovery Material on the record, before the
23 close of the deposition all protected testimony.
24 (c) for information produced in some form other than
25 documentary and for any other tangible items, that the Producing Party
26 affix in a prominent place on the exterior of the container or containers
27 in which the information is stored the “CONFIDENTIAL” legend. If only
28 a portion or portions of the information warrants protection, the
9
1 Producing Party, to the extent practicable, shall identify the protected
2 portion(s).
3 5.3 Inadvertent Failures to Designate. If timely corrected, an
4
inadvertent failure to designate qualified information or items does not,
5
standing alone, waive the Designating Party’s right to secure protection
6
under this Order for such material. Upon timely correction of a
7
designation, the Receiving Party must make reasonable efforts to assure
8
that the material is treated in accordance with the provisions of this
9
Stipulated Protective Order.
10
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6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
12
13 6.1 Timing of Challenges. Any Party or Non-Party may
14 challenge a designation of confidentiality at any time that is consistent
15 with the court’s Scheduling Order.
16 6.2 Meet and Confer. The Challenging Party shall initiate the
17 dispute resolution process under Local Rule 37.1 et seq. and with
18 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-
19 Discovery Motion Conference.”2
20 6.3 The burden of persuasion in any such challenge proceeding
21 shall be on the Designating Party. Frivolous challenges, and those
22
made for an improper purpose (e.g., to harass or impose unnecessary
23
expenses and burdens on other parties) may expose the Challenging
24
Party to sanctions. Unless the Designating Party has waived or
25
withdrawn the confidentiality designation, all parties shall continue to
26
27
2 Judge Christensen’s Procedures are available at
28 https://www.cacd.uscourts.gov/honorable-stephanie-s-christensen.
10
1 afford the material in question the level of protection to which it is
2 entitled under the Producing Party’s designation until the court rules on
3 the challenge.
4
5 7. ACCESS TO AND USE OF PROTECTED MATERIAL
6
7.1 Basic Principles. A Receiving Party may use Protected
7
Material that is disclosed or produced by another Party or by a Non-
8
Party in connection with this Action only for prosecuting, defending, or
9
attempting to settle this Action. Such Protected Material may be
10
disclosed only to the categories of persons and under the conditions
11
described in this Order. When the Action reaches a Final Disposition, a
12
Receiving Party must comply with the provisions of section 13 below.
13
14
Protected Material must be stored and maintained by a Receiving
15 Party at a location and in a secure manner that ensures that access is
16 limited to the persons authorized under this Stipulated Protective
17 Order.
18 7.2 Disclosure of “CONFIDENTIAL” Information or Items.
19 Unless otherwise ordered by the court or permitted in writing by the
20 Designating Party, a Receiving Party may disclose any information or
21 item designated “CONFIDENTIAL” only:
22 (a) to the Receiving Party’s Outside Counsel of Record in this
23 Action, as well as employees of said Outside Counsel of Record to whom
24 it is reasonably necessary to disclose the information for this Action;
25 (b) to the officers, directors, and employees (including House
26
Counsel) of the Receiving Party to whom disclosure is reasonably
27
necessary for this Action;
28
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1 (c) to Experts (as defined in this Order) of the Receiving Party to
2 whom disclosure is reasonably necessary for this Action and who have
3 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (d) to the court and its personnel;
5 (e) to court reporters and their staff;
6 (f) to professional jury or trial consultants, mock jurors, and
7 Professional Vendors to whom disclosure is reasonably necessary for
8
this Action and who have signed the “Acknowledgment and Agreement
9
to Be Bound” (Exhibit A);
10
(g) to the author or recipient of a document containing the
11
information or a custodian or other person who otherwise possessed or
12
knew the information;
13
(h) during their depositions, to witnesses, and attorneys for
14
witnesses, in the Action to whom disclosure is reasonably necessary,
15
provided: (1) the deposing party requests that the witness sign the
16
“Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
17
18
witness will not be permitted to keep any confidential information
19 unless they sign the “Acknowledgment and Agreement to Be Bound”
20 (Exhibit A), unless otherwise agreed by the Designating Party or
21 ordered by the court. Pages of transcribed deposition testimony or
22 exhibits to depositions that reveal Protected Material may be separately
23 bound by the court reporter and may not be disclosed to anyone except
24 as permitted under this Stipulated Protective Order; and
25 (i) to any mediator or settlement officer, and their supporting
26 personnel, mutually agreed upon by any of the parties engaged in
27 settlement discussions.
28
12
1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
2 PRODUCED IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in
4
other litigation that compels disclosure of any information or items
5
designated in this Action as “CONFIDENTIAL,” that Party must:
6
(a) promptly notify in writing the Designating Party. Such
7
notification shall include a copy of the subpoena or court order;
8
(b) promptly notify in writing the party who caused the
9
subpoena or order to issue in the other litigation that some or all of the
10
11 material covered by the subpoena or order is subject to this Protective
12 Order. Such notification shall include a copy of this Stipulated
13 Protective Order; and
14 (c) cooperate with respect to all reasonable procedures sought to
15 be pursued by the Designating Party whose Protected Material may be
16 affected.
17 If the Designating Party timely seeks a protective order, the
18 Party served with the subpoena or court order shall not produce any
19 information designated in this action as “CONFIDENTIAL” before a
20 determination by the court from which the subpoena or order issued,
21 unless the Party has obtained the Designating Party’s permission. The
22
Designating Party shall bear the burden and expense of seeking
23
protection in that court of its confidential material and nothing in these
24
provisions should be construed as authorizing or encouraging a
25
Receiving Party in this Action to disobey a lawful directive from another
26
court.
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1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 9.1 Application. The terms of this Stipulated Protective Order
4 are applicable to information produced by a Non-Party in this Action and
5 designated as “CONFIDENTIAL.” Such information produced by Non-
6 Parties in connection with this litigation is protected by the remedies
7 and relief provided by this Order. Nothing in these provisions should be
8
construed as prohibiting a Non-Party from seeking additional
9
protections.
10
9.2 Notification. In the event that a Party is required, by a valid
11
discovery request, to produce a Non-Party’s confidential information in
12
its possession, and the Party is subject to an agreement with the Non-
13
Party not to produce the Non-Party’s confidential information, then the
14
Party shall:
15
(a) promptly notify in writing the Requesting Party and the
16
Non-Party that some or all of the information requested is subject to a
17
confidentiality agreement with a Non-Party;
18
19
(b) make the information requested available for inspection by
20 the Non-Party, if requested.
21 9.3 Conditions of Production. If the Non-Party fails to seek a
22 protective order from this court within 14 days of receiving the notice
23 and accompanying information, the Receiving Party may produce the
24 Non-Party’s confidential information responsive to the discovery request.
25 If the Non-Party timely seeks a protective order, the Receiving Party
26 shall not produce any information in its possession or control that is
27 subject to the confidentiality agreement with the Non-Party before a
28 determination by the court. Absent a court order to the contrary, the
14
1 Non-Party shall bear the burden and expense of seeking protection in
2 this court of its Protected Material.
3
4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
5 MATERIAL
6
If a Receiving Party learns that, by inadvertence or otherwise, it
7
has disclosed Protected Material to any person or in any circumstance
8
not authorized under this Stipulated Protective Order, the Receiving
9
Party must immediately (a) notify in writing the Designating Party of
10
the unauthorized disclosures, (b) use its best efforts to retrieve all
11
unauthorized copies of the Protected Material, (c) inform the person or
12
persons to whom unauthorized disclosures were made of all the terms of
13
14
this Order, and (d) request such person or persons to execute the
15 “Acknowledgment and Agreement to Be Bound” (Exhibit A).
16
17 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
18 OTHERWISE PROTECTED MATERIAL
19
When a Producing Party gives notice to Receiving Parties that
20
certain inadvertently produced material is subject to a claim of privilege
21
or other protection, the obligations of the Receiving Parties are those set
22
forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This
23
provision is not intended to modify whatever procedure may be
24
established in an e-discovery order that provides for production without
25
prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
26
Rules of Evidence, insofar as the parties reach an agreement on the
27
effect of disclosure of a communication or information covered by the
28
15
1 attorney-client privilege or work product protection, the parties may
2 incorporate their agreement in the stipulated protective order
3 submitted to the court.
4
5 12. MISCELLANEOUS
6
12.1 Right to Further Relief. Nothing in this Stipulated
7
Protective Order abridges the right of any person to seek its
8
modification by the court in the future.
9
12.2 Right to Assert Other Objections. By stipulating to the entry
10
of this Stipulated Protective Order no Party waives any right it
11
otherwise would have to object to disclosing or producing any
12
information or item on any ground not addressed in this Stipulated
13
14
Protective Order. Similarly, no Party waives any right to object on any
15 ground to use in evidence of any of the material covered by this
16 Stipulated Protective Order.
17 12.3 Filing Protected Material. A Party that seeks to file under
18 seal any Protected Material must comply with Local Rule 79-5.
19 Protected Material may only be filed under seal pursuant to a court
20 order authorizing the sealing of the specific Protected Material at issue.
21 If a Party's request to file Protected Material under seal is denied by the
22 court, then the Receiving Party may file the information in the public
23 record unless otherwise instructed by the court.
24
25 13. FINAL DISPOSITION
26
After the Final Disposition of this Action, as defined in paragraph
27
4, within 60 days of a written request by the Designating Party, each
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16
1 Receiving Party must return all Protected Material to the Producing
2 Party or destroy such material. As used in this subdivision, “all
3 Protected Material” includes all copies, abstracts, compilations,
4 summaries, and any other format reproducing or capturing any of the
5 Protected Material. Whether the Protected Material is returned or
6 destroyed, the Receiving Party must submit a written certification to
7 the Producing Party (and, if not the same person or entity, to the
8
Designating Party) by the 60 day deadline that (1) identifies (by
9
category, where appropriate) all the Protected Material that was
10
returned or destroyed and (2) affirms that the Receiving Party has not
11
retained any copies, abstracts, compilations, summaries or any other
12
format reproducing or capturing any of the Protected Material.
13
Notwithstanding this provision, Counsel is entitled to retain an archival
14
copy of all pleadings, motion papers, trial, deposition, and hearing
15
transcripts, legal memoranda, correspondence, deposition and trial
16
exhibits, expert reports, attorney work product, and consultant and
17
expert work product, even if such materials contain Protected Material.
18
19
Any such archival copies that contain or constitute Protected Material
20 remain subject to this Protective Order as set forth in Section 4.
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1 14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished
3 by any and all appropriate measures including, without limitation,
4 contempt proceedings and/or monetary sanctions.
5
6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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DATED:_____________ ________________________________
9
Attorney(s) for Plaintiff(s)
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DATED:_____________ ______________________________
12
Attorney(s) for Defendant(s)
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16 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
17
18 DATED:_____________ _________________________________
19 STEPHANIE S. CHRISTENSEN
United States Magistrate Judge
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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
5
penalty of perjury that I have read in its entirety and understand the
6
Stipulated Protective Order that was issued by the United States
7
District Court for the Central District of California on [date] in the
8
case of __________ [insert formal name of the case and the
9
10
number and initials assigned to it by the court]. I agree to
11 comply with and to be bound by all the terms of this Stipulated
12 Protective Order and I understand and acknowledge that failure to so
13 comply could expose me to sanctions and punishment in the nature of
14 contempt. I solemnly promise that I will not disclose in any manner
15 any information or item that is subject to this Stipulated Protective
16 Order to any person or entity except in strict compliance with the
17 provisions of this Order.
18 I further agree to submit to the jurisdiction of the United States
19 District Court for the Central District of California for the purpose of
20 enforcing the terms of this Stipulated Protective Order, even if such
21 enforcement proceedings occur after termination of this action. I
22
hereby appoint ________________________ [print or type full name]
23
of _________ [print or type full address and telephone number] as
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1 my California agent for service of process in connection with this action
2 or any proceedings related to enforcement of this Stipulated Protective
3 Order.
4
5 Date: ___________________________
6 City and State where sworn and
7 ___________________________
signed:
8
Printed name: ___________________________
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Signature: ___________________________
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