JJaammeess. CP.a Crtearr@terj a(SckBsNon 1le5w00is5.2co) m 2 Kelli M. Dreger (SBN 267404) [email protected] 3 JACKSON LEWIS P.C. 200 Spectrum Center Drive, Suite 500 4 Irvine, CA 92618 Telephone: (949) 885-1360 5 Facsimile: (949) 885-1380

6 Attorneys for Plaintiff PERKINELMER HEALTH SCIENCES, INC., 7 PERKINELMER GENETICS, INC., and PERKINLEMER, INC. 8 UNITED STATES DISTRICT COURT 9

10 CENTRAL DISTRICT OF CALIFORNIA 11 12 PERKINELMER HEALTH SCIENCES, CASE NO.: 2:21-cv-1619-DMG-KS INC., a Delaware Corporation, Assigned to the Hon. Dolly M. Gee 13 PERKINELMER GENETICS, INC., a Pennsylvania Corporation, and 14 PERKINELMER, INC. a Massachusetts Corporation. [PROPOSED] PROTECTIVE ORDER 15 Plaintiffs, 16 vs. 17 Complaint Filed: February 22, 2021 MAHNAZ SALEM, an individual; and 18 DOES 1 through 25, inclusive, 19 Defendants. 20 21

22 1. PURPOSES AND LIMITATIONS 23 Discovery in this action is likely to involve production of confidential, proprietary, 24 or private information for which special protection from public disclosure and from use 25 for any purpose other than prosecuting this litigation may be warranted. Accordingly, 26 Plaintiffs PerkinElmer Health Sciences, Inc., PerkinElmer Genetics, Inc. and 27 PerkinElmer, Inc. (“PerkinElmer” or “Plaintiffs”) hereby petition the Court to enter the 28 following Protective Order. This Order does not confer blanket protections on all 2 disclosures or responses to discovery and that the protection it affords from public 3 disclosure and use extends only to the limited information or items that are entitled to 4 confidential treatment under the applicable legal principles. It is further acknowledged, as 5 set forth in Section 13.3, below, that this Protective Order does not entitle them to file 6 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that 7 must be followed and the standards that will be applied when a party seeks permission 8 from the court to file material under seal. 9 2. GOOD CAUSE STATEMENT 10 This action is likely to involve confidential information and other information 11 protected by the right of privacy, trade secrets, customer lists, customer account 12 information, development, commercial, financial, technical and/or proprietary 13 information for which special protection from public disclosure and from use for any 14 purpose other than prosecution of this action is warranted. Such confidential and 15 proprietary materials and information consist of, among other things, confidential 16 business or financial information, information regarding confidential business practices, 17 or other confidential research, development, or commercial information (including 18 information implicating privacy rights of third parties), information otherwise generally 19 unavailable to the public, or which may be privileged or otherwise protected from 20 disclosure under state or federal statutes, court rules, case decisions, or common law. 21 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 22 disputes over confidentiality of discovery materials, to adequately protect information the 23 parties are entitled to keep confidential, to ensure that the parties are permitted reasonable 24 necessary uses of such material in preparation for and in the conduct of trial, to address 25 their handling at the end of the litigation, and serve the ends of justice, a protective order 26 for such information is justified in this matter. Information will not be designated as 27 confidential for tactical reasons and that nothing be so designated without a good faith 28 belief that it has 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 3. DEFINITIONS 4 3.1 Action: PerkinElmer Health Sciences, Inc., PerkinElmer Genetics, Inc. and 5 PerkinElmer, Inc. v. Mahnaz Salem, Case No. 2:21-cv-1619-DMG-KS. 6 3.2 Challenging Party: a Party or Non-Party that challenges the designation of 7 information or items under this Order. 8 3.3 “CONFIDENTIAL” Information or Items: information (regardless of how it 9 is generated, stored or maintained) or tangible things that qualify for protection under 10 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 11 Statement. 12 3.4 “HIGHLY CONFIDENTIAL” Information or Items: extremely sensitive 13 “CONFIDENTIAL” Information or Items, the disclosure of which to another Party or 14 Non-Party would create a substantial risk of serious harm that could not be avoided by 15 less restrictive means. 16 3.5 Counsel: Outside Counsel of Record and House Counsel (as well as their 17 support staff). 18 3.6 Designating Party: a Party or Non-Party that designates information or items 19 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL” or 20 “HIGHLY CONFIDENTIAL.” 21 3.7 Disclosure or Discovery Material: all items or information, regardless of the 22 medium or manner in which it is generated, stored, or maintained (including, among 23 other things, testimony, transcripts, and tangible things), that are produced or generated in 24 disclosures or responses to discovery in this matter. 25 3.8 Expert: a person with specialized knowledge or experience in a matter 26 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 27 expert witness or as a consultant in this Action. 28 3.9 House Counsel: attorneys who are employees of a party to this Action. 2 House Counsel does not include Outside Counsel of Record or any other outside counsel. 3 3.10 Non-Party: any natural person, partnership, corporation, association, or other 4 legal entity not named as a Party to this action. 5 3.11 Outside Counsel of Record: attorneys who are not employees of a party to 6 this Action but are retained to represent or advise a party to this Action and have 7 appeared in this Action on behalf of that party or are affiliated with a law firm that has 8 appeared on behalf of that party, including support staff. 9 3.12 Party: any party to this Action, including all of its officers, directors, 10 employees, consultants, retained experts, and Outside Counsel of Record (and their 11 support staffs). 12 3.13 Producing Party: a Party or Non-Party that produces Disclosure or 13 Discovery Material in this Action. 14 3.14 Professional Vendors: persons or entities that provide litigation support 15 services (e.g., photocopying, videotaping, translating, preparing exhibits or 16 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 17 their employees and subcontractors. 18 3.15 Protected Material: any Disclosure or Discovery Material that is designated 19 as “CONFIDENTIAL or “HIGHLY CONFIDENTIAL.” 20 3.16 Receiving Party: a Party that receives Disclosure or Discovery Material from 21 a Producing Party. 22 4. SCOPE 23 The protections conferred by this Order cover not only Protected Material (as 24 defined above), but also (1) any information copied or extracted from Protected Material; 25 (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any 26 testimony, conversations, or presentations by Parties or their Counsel that might reveal 27 Protected Material. Any use of Protected Material at trial shall be governed by the orders 28 of the trial judge. This Order does not govern the use of Protected Material at trial. 5. DURATION 2 Once a case proceeds to trial, all of the court-filed information to be introduced 3 that was previously designated as confidential or maintained pursuant to this protective 4 order becomes public and will be presumptively available to all members of the public, 5 including the press, unless compelling reasons supported by specific factual findings to 6 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v. 7 City and County of Honolulu,

(9th Cir. 2006) (distinguishing 8 “good cause” showing for sealing documents produced in discovery from “compelling 9 reasons” standard when merits-related documents are part of court record). Accordingly, 10 the terms of this protective order do not extend beyond the commencement of the trial. 11 6. DESIGNATING PROTECTED MATERIAL 12 6.1 Exercise of Restraint and Care in Designating Material for Protection. Each 13 Party or Non-Party that designates information or items for protection under this Order 14 must take care to limit any such designation to specific material that qualifies under the 15 appropriate standards. The Designating Party must designate for protection only those 16 parts of material, documents, items, or oral or written communications that qualify so that 17 other portions of the material, documents, items, or communications for which protection 18 is not warranted are not swept unjustifiably within the ambit of this Order. 19 Mass, indiscriminate, or routinized designations are prohibited. Designations that 20 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 21 to unnecessarily encumber the case development process or to impose unnecessary 22 expenses and burdens on other parties) may expose the Designating Party to sanctions. 23 If it comes to a Designating Party’s attention that information or items that it 24 designated for protection do not qualify for protection, that Designating Party must 25 promptly notify all other Parties that it is withdrawing the inapplicable designation. 26 6.2 Manner and Timing of Designations. Except as otherwise provided in this 27 Order (see, e.g., second paragraph of section 7.2(a) below), or as otherwise stipulated or 28 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 2 must be clearly so designated before the material is disclosed or produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or electronic documents, 5 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 6 Producing Party affix, at a minimum, the legend “CONFIDENTIAL” or “HIGHLY 7 CONFIDENTIAL”, to each page that contains protected material. If only a portion or 8 portions of the material on a page qualifies for protection, the Producing Party also must 9 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 10 margins). 11 A Party or Non-Party that makes original documents available for inspection need 12 not designate them for protection until after the inspecting Party has indicated which 13 documents it would like copied and produced. During the inspection and before the 14 designation, all of the material made available for inspection shall be deemed 15 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” After the inspecting Party has 16 identified the documents it wants copied and produced, the Producing Party must 17 determine which documents, or portions thereof, qualify for protection under this Order. 18 Then, before producing the specified documents, the Producing Party must affix a 19 CONFIDENTIAL legend or HIGHLY CONFIDENTIAL legend to each page that 20 contains Protected Material. If only a portion or portions of the material on a page 21 qualifies for protection, the Producing Party also must clearly identify the protected 22 portion(s) (e.g., by making appropriate markings in the margins). 23 (b) for testimony given in depositions that the Designating Party identify the 24 Disclosure or Discovery Material on the record, before the close of the deposition. 25 (c) for information produced in some form other than documentary and for 26 any other tangible items, that the Producing Party affix in a prominent place on the 27 exterior of the container or containers in which the information is stored the legend 28 “CONFIDENTIAL or “HIGHLY CONFIDENTIAL.” If only a portion or portions of the information warrants protection, the Producing Party, to the extent practicable, shall 2 identify the protected portion(s). 3 6.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 4 to designate qualified information or items does not, standing alone, waive the 5 Designating Party’s right to secure protection under this Order for such material. Upon 6 timely correction of a designation, the Receiving Party must make reasonable efforts to 7 assure that the material is treated in accordance with the provisions of this Order. 8 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 9 7.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 10 of confidentiality at any time. 11 7.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 12 process under Local Rule 37.1, et seq. Any discovery motion must strictly comply with 13 the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 14 7.3 Burden. The burden of persuasion in any such challenge proceeding shall be 15 on the Designating Party. Frivolous challenges, and those made for an improper purpose 16 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may expose 17 the Challenging Party to sanctions. Unless the Designating Party has waived or 18 withdrawn the confidentiality designation, all parties shall continue to afford the material 19 in question the level of protection to which it is entitled under the Producing Party’s 20 designation until the Court rules on the challenge. 21 8. ACCESS TO AND USE OF PROTECTED MATERIAL 22 8.1 Basic Principles. A Receiving Party may use Protected Material that is 23 disclosed or produced by another Party or by a Non-Party in connection with this Action 24 only for prosecuting, defending, or attempting to settle this Action. Such Protected 25 Material may be disclosed only to the categories of persons and under the conditions 26 described in this Order. When the Action has been terminated, a Receiving Party must 27 comply with the provisions of section 14 below (FINAL DISPOSITION). Protected 28 Material must be stored and maintained by a Receiving Party at a location and in a secure 2 manner that ensures that access is limited to the persons authorized under this Order. 3 8.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 4 ordered by the Court or permitted in writing by the Designating Party, a Receiving Party 5 may disclose any information or item designated “CONFIDENTIAL” only to: 6 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 7 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 8 disclose the information for this Action; 9 (b) the officers, directors, and employees (including House Counsel) of the 10 Receiving Party to whom disclosure is reasonably necessary for this Action; 11 (c) Experts (as defined in this Order) of the Receiving Party to whom 12 disclosure is reasonably necessary for this Action and who have signed the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (d) the Court and its personnel; 15 (e) court reporters and their staff; 16 (f) professional jury or trial consultants, mock jurors, and Professional 17 Vendors to whom disclosure is reasonably necessary for this Action and who have signed 18 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (g) the author or recipient of a document containing the information or a 20 custodian or other person who otherwise possessed or knew the information; 21 (h) during their depositions, witnesses, and attorneys for witnesses, in the 22 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 23 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not 24 be permitted to keep any confidential information unless they sign the “Acknowledgment 25 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 26 Party or ordered by the Court. Pages of transcribed deposition testimony or exhibits to 27 depositions that reveal Protected Material may be separately bound by the court reporter 28 and may not be disclosed to anyone except as permitted under this Protective Order; and (i) any mediator or settlement officer, and their supporting personnel, 2 mutually agreed upon by any of the parties engaged in settlement discussions. 3 8.3 Disclosure of “HIGHLY CONFIDENTIAL” Information or Items. Unless 4 otherwise ordered by the court or permitted in writing by the Designating Party, a 5 Receiving Party may disclose any information or item designated “HIGHLY 6 CONFIDENTIAL” only to: 7 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 8 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 9 disclose the information for this Action; 10 (b) Experts (as defined in this Order) of the Receiving Party to whom 11 disclosure is reasonably necessary for this Action and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (c) the court and its personnel; 14 (d) private court reporters and their staff to whom disclosure is reasonably 15 necessary for this Action and who have signed the “Acknowledgment and Agreement to 16 Be Bound” (Exhibit A); 17 (e) professional jury or trial consultants, mock jurors, and Professional 18 Vendors to whom disclosure is reasonably necessary for this Action and who have signed 19 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (f) the author or recipient of a document containing the information or a 21 custodian or other person who otherwise possessed or knew the information; and 22 (g) any mediator or settlement officer, and their supporting personnel, 23 mutually agreed upon by any of the parties engaged in settlement discussions. 24 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 25 OTHER LITIGATION 26 If a Party is served with a subpoena or a court order issued in other litigation that 27 compels disclosure of any information or items designated in this Action as 28 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification shall 2 include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or order to 4 issue in the other litigation that some or all of the material covered by the subpoena or 5 order is subject to this Protective Order. Such notification shall include a copy of this 6 Protective Order; and 7 (c) cooperate with respect to all reasonable procedures sought to be pursued 8 by the Designating Party whose Protected Material may be affected. 9 If the Designating Party timely seeks a protective order, the Party served with the 10 subpoena or court order shall not produce any information designated in this action as 11 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” before a determination by the 12 court from which the subpoena or order issued, unless the Party has obtained the 13 Designating Party’s permission. The Designating Party shall bear the burden and expense 14 of seeking protection in that court of its confidential material and nothing in these 15 provisions should be construed as authorizing or encouraging a Receiving Party in this 16 Action to disobey a lawful directive from another court. 17 10. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 18 PRODUCED IN THIS LITIGATION 19 (a) The terms of this Order are applicable to information produced by a Non- 20 Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 21 CONFIDENTIAL.” Such information produced by Non-Parties in connection with this 22 litigation is protected by the remedies and relief provided by this Order. Nothing in these 23 provisions should be construed as prohibiting a Non-Party from seeking additional 24 protections. 25 (b) In the event that a Party is required, by a valid discovery request, to 26 produce a NonParty’s confidential information in its possession, and the Party is subject 27 to an agreement with the Non-Party not to produce the Non-Party’s confidential 28 information, then the Party shall: (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 Protective Order 5 in this Action, the relevant discovery request(s), and a reasonably specific description of 6 the information requested; and 7 (3) make the information requested available for inspection by the Non- 8 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. If 12 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 13 information in its possession or control that is subject to the confidentiality agreement 14 with the Non-Party before a determination by the Court. Absent a court order to the 15 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 16 Court of its Protected Material. 17 11. 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 Protective Order, the Receiving Party must immediately (a) notify in writing the 21 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 22 unauthorized copies of the Protected Material, (c) inform the person or persons to whom 23 unauthorized disclosures were made of all the terms of this Order, and (d) request such 24 person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is 25 attached hereto as Exhibit A. 26 / / / 27 / / / 28 / / / 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 Pursuant to Rule 502 of the Federal Rules of Evidence, the inadvertent disclosure 4 of communications, documents, or information protected by the attorney-client privilege, 5 work product doctrine, or any other privilege (“Privileged Material”) shall not constitute 6 a waiver of any privilege or other protection if the Producing Party took reasonable steps 7 to prevent disclosure and also took reasonable steps to rectify the error in the event of an 8 inadvertent disclosure. The Producing Party will be deemed to have taken reasonable 9 steps to prevent Privileged Material from inadvertent disclosure if that party utilized 10 either attorney screening, keyword search term screening, advanced analytical software 11 applications and/or linguistic tools in screening for privilege, work product, or other 12 protection. In the event of the inadvertent disclosure of Privileged Material, the 13 Producing Party shall be deemed to have taken reasonable steps to rectify the error of the 14 disclosure if, within thirty (30) days from the date that the inadvertent disclosure was 15 discovered or brought to the attention of the Producing Party, the Producing Party notifies 16 the Receiving Party of the inadvertent disclosure and instructs the Receiving Party to 17 promptly sequester, return, delete, or destroy all copies of the inadvertently produced 18 Privileged Material (including any and all work product containing such Privileged 19 Material). The Receiving Party also has an affirmative obligation to notify the Producing 20 Party if it receives communications, documents, or information that appear to constitute 21 Privileged Material. Upon receiving such a request from the Producing Party, the 22 Receiving Party shall promptly sequester, return, delete, or destroy all copies of such 23 inadvertently produced Privileged Material (including any and all work product 24 containing such Privileged Material), and shall make no further use of such Privileged 25 Material (or work product containing such Privileged Material). 26 13. MISCELLANEOUS 27 13.1 Right to Further Relief. Nothing in this Order abridges the right of any 28 person to seek its modification by the Court in the future. 13.2 Right to Assert Other Objections. Through entry of this Protective Order, no 2 Party waives any right it otherwise would have to object to disclosing or producing any 3 information or item on any ground not addressed in this Protective Order. Similarly, no 4 Party waives any right to object on any ground to use in evidence of any of the material 5 covered by this Protective Order. The entering of the Protective Order and subsequent 6 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” designation does not prohibit a 7 Party from redacting privileged, irrelevant and/or private confidential information from 8 documents designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” 9 13.3 Filing Protected Material. A Party that seeks to file under seal any Protected 10 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 11 under seal pursuant to a court order authorizing the sealing of the specific Protected 12 Material at issue; good cause must be shown in the request to file under seal. If a Party’s 13 request to file Protected Material under seal is denied by the Court, then the Receiving 14 Party may file the information in the public record unless otherwise instructed by the 15 Court. 16 14. FINAL DISPOSITION 17 After the final disposition of this Action, within 60 days of a written request by the 18 Designating Party, each Receiving Party must return all Protected Material to the 19 Producing Party or destroy such material. As used in this subdivision, “all Protected 20 Material” includes all copies, abstracts, compilations, summaries, and any other format 21 reproducing or capturing any of the Protected Material. Whether the Protected Material is 22 returned or destroyed, the Receiving Party must submit a written certification to the 23 Producing Party (and, if not the same person or entity, to the Designating Party) by the 60 24 day deadline that (1) identifies (by category, where appropriate) all the Protected Material 25 that was returned or destroyed and (2) affirms that the Receiving Party has not retained 26 any copies, abstracts, compilations, summaries or any other format reproducing or 27 capturing any of the Protected Material. Notwithstanding this provision, counsel are 28 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and 1 || hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, 2 || expert reports, attorney work product, and consultant and expert work product, even if 3 materials contain Protected Material. Any such archival copies that contain or 4 || constitute Protected Material remain subject to this Protective Order as set forth in 5 || Section 5 (DURATION). 6 Any violation of this Order may be punished by any and all appropriate measures 7 ||including, without limitation, contempt proceedings and/or monetary sanctions. 8 9 Dated: April 12, 2021 10 /s/ Kelli M. Dreger 11 James P. Carter / Kelli M. Dreger 12 Atomeys for Plain 13 PorkiEWner Healt O° Tae eid PerkinElmer, Inc. 14 15 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

17 Dated: April 15, 2021

19

Karen L. Stevenson United States Magistrate Judge 23 24 25 26 27 28

EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _______________________ [print or type full name], of 4 [print or type full address], declare under penalty of perjury that I have read in its 5 entirety and understand the Protective Order that was issued by the United States District 6 Court for the Central District of California on ______ in the case of PerkinElmer Health 7 Sciences, Inc., PerkinElmer Genetics, Inc. and PerkinElmer, Inc. v. Mahnaz Salem, Case 8 No. 2:21-cv-1619-DMG-KS. I agree to comply with and to be bound by all the terms of 9 this Protective Order and I understand and acknowledge that failure to so comply could 10 expose me to sanctions and punishment in the nature of contempt. I solemnly promise 11 that I will not disclose in any manner any information or item that is subject to this 12 Protective Order to any person or entity except in strict compliance with the provisions of 13 this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for the purpose of enforcing the terms of this Protective 16 Order, even if such enforcement proceedings occur after termination of this action. I 17 hereby appoint [print or type full name] of 18 _____________________________________ [print or type full address and telephone 19 number] as my California agent for service of process in connection with this action or 20 any proceedings related to enforcement of this Protective Order. 21

22 Printed name: _______________________________ 23 24 Signature: _____________________________ 25 26 27 28