1 EPSTEIN DRANGEL LLP Jeffrey A. Kobulnick - Bar No. 228299 Peter J. Farnese (SBN 251204) Mark D. Brutzkus - Bar No. 128102 2 [email protected] Michael A. Bernet - Bar No. 306657 11601 Wilshire Blvd., Suite 500 3 BRUTZKUS GUBNER Los Angeles, California 90025 21650 Oxnard Street, Suite 500 4 Telephone: 310-356-4668 Facsimile: 310-388-1232 Woodland Hills, CA 91367 5 Telephon e: (818) 827-9000 Ashly E. Sands, pro hac vice Facsimile: (818) 827-9099 6 [email protected] Email: [email protected] 7 60 East 42nd Street, Suite 2520 [email protected] New York, New York 10165 [email protected] 8 Telephone: 212-292-5390 Facsimile: 212-292-5391 Attorneys for Defendant and Counter- 9 Attorneys for Plaintiff and Claimant,

10 Counterclaim-Defendant, A

LL ACCESS APPAREL, INC. Happy Ashley Ltd.

11

UNITED STATES DISTRICT COURT 12

FOR THE CENTRAL DISTRICT OF CALIFORNIA 13

14

Happy Ashley Ltd., CASE No. 2:20-cv-9702-DMG-SK 15

16 Plaintiff and Counterclaim- Defendant, STIPULATED PROTECTIVE 17 ORDER v. 18 All Access Apparel, Inc. 19 Defendant and 20 Counterclaim-Plaintiff.

21

22 1. A. PURPOSE AND LIMITATIONS

23

24 Discovery in this action is likely to involve production of confidential, proprietary,

25 or private information for which special protection from public disclosure and from use

26 for any purpose other than prosecuting this litigation may be warranted. Accordingly,

27 the parties hereby stipulate to and petition the Court to enter the following Stipulated 28 Protective Order. The parties acknowledge that this Order does not confer blanket 1 protections on all disclosures or responses to discovery and that the protection it affords

2 from public disclosure and use extends only to the limited information or items that are

3 entitled to confidential treatment under the applicable legal principles. The parties

4 further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective

5 Order does not entitle them to file confidential infor mation under seal; Civil Local Rule

6 79-5 sets forth the procedures that must be followed and the standards that will be

7 applied when a party seeks permission from the court to file material under seal.

8

9 B. GOOD CAUSE STATEMENT

10 This action is likely to involve trade secrets, customer and pricing lists, financial

11 revenue and profit information, marketing strategies, and other valuable research,

12 development, commercial, financial, technical and/or proprietary information for which

13 special protection from public disclosure and from use for any purpose other than

14 prosecution of this action is warranted. Such confidential and proprietary materials and

15 information consist of, among other things, confidential business or financial

16 information, information regarding confidential business practices, or other confidential

17 research, development, or commercial information (including information implicating

18 privacy rights of third parties), information otherwise generally unavailable to the

19 public, or which may be privileged or otherwise protected from disclosure under state or

20 federal statutes, court rules, case decisions, or common law. Accordingly, to expedite

21 the flow of information, to facilitate the prompt resolution of disputes over

22 confidentiality of discovery materials, to adequately protect information the Parties are

23 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

26 order for such 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 and that nothing 28 be so designated without a good faith belief that it has been maintained in a confidential, 1 non-public manner, and there is good cause why it should not be part of the public

2 record of this case.

3 Additionally, here, there is a need for a two-tiered, attorneys’ eyes only protective

4 order that designates certain material as “HIGHLY CONFIDENTIAL – ATTORNEYS’

5 EYES ONLY”. See Elements Spirits, Inc. v. Iconic Brands, Inc., Civ. No. CV 15-02692

6 DDP(AGRx),

, at *1–*2 (C.D. Cal. May 9, 2016) (holding that

7 protective order with attorneys’ eyes only designation was warranted to protect party’s

8 confidential information) (citing Nutratech, Inc. v. Syntech Int’l, Inc.,

,

9 555 (C.D. Cal. 2008); Brown Bag Software v. Symantec Corp.,

, 1470

10 (9th Cir. 1992)).

11

12 2. DEFINITIONS

13 2.1 Action: this pending federal law suit, Happy Ashley Ltd. v. All Access

14 Apparel, Inc., Case No. 2:20-cv-9702-DMG-SK.

15 2.2 Challenging Party: a Party or Non-Party that challenges the designation of

16 information or items under this Order.

17 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how

18 it is generated, stored or maintained) or tangible things that qualify for protection under

19 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

20 Statement.

21 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

22 support staff).

23 2.5 Designating Party: a Party or Non-Party that designates information or

24 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL”

25 or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”

26 2.6 Disclosure or Discovery Material: all items or information, regardless of

27 the medium or manner in which it is generated, stored, or maintained (including, among 28 1 other things, testimony, transcripts, and tangible things), that are produced or generated

2 in disclosures or responses to discovery in this matter.

3 2.7 Expert: a person with specialized knowledge or experience in a matter

4 pertinent to the litigation who has been retained by a Party or its counsel to serve as an

5 expert witness or as a consultant in this Action.

6 2.8 House Counsel: attorneys who are employees of a party to this Action. House

7 Counsel does not include Outside Counsel of Record or any other outside counsel.

8 2.9 Non-Party: any natural person, partnership, corporation, association, or

9 other legal entity not named as a Party to this action.

10 2.10 Outside Counsel of Record: attorneys who are not employees of a party to

11 this Action but are retained to represent or advise a party to this Action and have

12 appeared in this Action on behalf of that party or are affiliated with a law firm which

13 has appeared on behalf of that party, and includes support staff.

14 2.11 Party: any party to this Action, including all of its officers, directors,

15 employees, consultants, retained experts, and Outside Counsel of Record (and their

16 support staffs).

17 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

18 Discovery Material in this Action.

19 2.13 Professional Vendors: persons or entities that provide litigation support

20 services (e.g., photocopying, videotaping, translating, preparing exhibits or

21 demonstrations, and organizing, storing, or retrieving data in any form or medium) and

22 their employees and subcontractors.

23 2.14 Protected Material: any Disclosure or Discovery Material that is designated

24 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

25 ONLY.”

26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

27 from a Producing Party. 28 1 2.16 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”

2 Information or Items: information or items that is/are extremely confidential and/or

3 sensitive, the disclosure of which to any other Party or Non-Party would create a

4 substantial risk of serious harm, including competitive injury, that could not be avoided

5 by less restrictive means.

6

7 3. SCOPE

8 The protections conferred by this Stipulation and Order cover not only Protected

9 Material (as defined above), but also (1) any information copied or extracted from

10 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

11 Material; and (3) any testimony, conversations, or presentations by Parties or their

12 Counsel that might reveal Protected Material.

13 Any use of Protected Material at trial shall be governed by the orders of the trial

14 judge. This Order does not govern the use of Protected Material at trial.

15 4. DURATION

16 Even after final disposition of this litigation, the confidentiality obligations

17 imposed by this Order shall remain in effect until a Designating Party agrees otherwise

18 in writing or a court order otherwise directs. Final disposition shall be deemed to be the

19 later of (1) dismissal of all claims and defenses in this Action, with or without prejudice;

20 and (2) final judgment herein after the completion and exhaustion of all appeals,

21 rehearings, remands, trials, or reviews of this Action, including the time limits for filing

22 any motions or applications for extension of time pursuant to applicable law.

23

24 5. DESIGNATING PROTECTED MATERIAL

25 5.1 Exercise of Restraint and Care in Designating Material for Protection.

26 Each Party or Non-Party that designates information or items for protection under this

27 Order must take care to limit any such designation to specific material that qualifies 28 under the appropriate standards. The Designating Party must designate for protection 1 only those parts of material, documents, items, or oral or written communications that

2 qualify so that other portions of the material, documents, items, or communications for

3 which protection is not warranted are not swept unjustifiably within the ambit of this

4 Order.

5 Mass, indiscriminate, or routinized designatio ns are prohibited. Designations that

6 are shown to be clearly unjustified or that have been made for an improper purpose

7 (e.g., to unnecessarily encumber the case development process or to impose unnecessary

8 expenses and burdens on other parties) may expose the Designating Party to sanctions.

9 If it comes to a Designating Party’s attention that information or items that it

10 designated for protection do not qualify for protection, that Designating Party must

11 promptly notify all other Parties that it is withdrawing the inapplicable designation.

12 5.2 Manner and Timing of Designations. Except as otherwise provided in this

13 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or

14 ordered, Disclosure or Discovery Material that qualifies for protection under this Order

15 must be clearly so designated before the material is disclosed or produced.

16 Designation in conformity with this Order requires:

17 (a) for information in documentary form (e.g., paper or electronic documents, but

18 excluding transcripts of depositions or other pretrial or trial proceedings), that the

19 Producing Party affix at a minimum, the legend “CONFIDENTIAL” or “HIGHLY

20 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” (hereinafter “CONFIDENTIAL

21 legend”), to each page that contains protected material. If only a portion or portions of

22 the material on a page qualifies for protection, the Producing Party also must clearly

23 identify the protected portion(s) (e.g., by making appropriate markings in the margins).

24 A Party or Non-Party that makes original documents available for Inspection need

25 not designate them for protection until after the inspecting Party has indicated which

26 documents it would like copied and produced. During the inspection and before the

27 designation, all of the material made available for inspection shall be deemed 28 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 1 copied and produced, the Producing Party must determine which documents, or portions

2 thereof, qualify for protection under this Order. Then, before producing the specified

3 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page

4 that contains Protected Material. If only a portion or portions of the material on a page

5 qualifies for protection, the Producing Party also must clearly identify the protected

6 portion(s) (e.g., by making appropriate markings in the margins).

7 (b) for testimony given in depositions that the Designating Party identify the

8 Disclosure or Discovery Material on the record, before the close of the deposition all

9 protected testimony.

10 (c) for information produced in some form other than documentary and for any

11 other tangible items, that the Producing Party affix in a prominent place on the exterior

12 of the container or containers in which the information is stored the legend

13 “CONFIDENTIAL.” If only a portion or portions of the information warrants

14 protection, the Producing Party, to the extent practicable, shall identify the protected

15 portion(s).

16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

17 to designate qualified information or items does not, standing alone, waive the

18 Designating Party’s right to secure protection under this Order for such material. Upon

19 timely correction of a designation, the Receiving Party must make reasonable efforts to

20 assure that the material is treated in accordance with the provisions of this Order.

21

22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

23 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

24 designation of confidentiality at any time that is consistent with the Court’s Scheduling

25 Order.

26 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

27 resolution process under Local Rule 37.1 et seq. 28 1 6.3 The burden of persuasion in any such challenge proceeding shall be on the

2 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,

3 to harass or impose unnecessary expenses and burdens on other parties) may expose the

4 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn

5 the confidentiality designation, all parties shall c ontinue to afford the material in

6 question the level of protection to which it is entitled under the Producing Party’s

7 designation until the Court rules on the challenge.

8

9 7. ACCESS TO AND USE OF PROTECTED MATERIAL

10 7.1 Basic Principles. A Receiving Party may use Protected Material that is

11 disclosed or produced by another Party or by a Non-Party in connection with this Action

12 only for prosecuting, defending, or attempting to settle this Action. Such Protected

13 Material may be disclosed only to the categories of persons and under the conditions

14 described in this Order. When the Action has been terminated, a Receiving Party must

15 comply with the provisions of section 13 below (FINAL DISPOSITION).

16 Protected Material must be stored and maintained by a Receiving Party at a

17 location and in a secure manner that ensures that access is limited to the persons

18 authorized under this Order.

19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

20 ordered by the court or permitted in writing by the Designating Party, a Receiving Party

21 may disclose any information or item designated “CONFIDENTIAL” only to:

22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as

23 employees of said Outside Counsel of Record to whom it is reasonably necessary to

24 disclose the information for this Action;

25 (b) the officers, directors, and employees (including House Counsel) of the

26 Receiving Party to whom disclosure is reasonably necessary for this Action;

27 28 1 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure

2 is reasonably necessary for this Action and who have signed the “Acknowledgment and

3 Agreement to Be Bound” (Exhibit A);

4 (d) the court and its personnel;

5 (e) court reporters and their staff;

6 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to

7 whom disclosure is reasonably necessary for this Action and who have signed the

8 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

9 (g) the author or recipient of a document containing the information or a

10 custodian or other person who otherwise possessed or knew the information;

11 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action

12 to whom disclosure is reasonably necessary provided: (1) the deposing party requests

13 that the witness sign the form attached as Exhibit A hereto; and (2) they will not be

14 permitted to keep any confidential information unless they sign the “Acknowledgment

15 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating

16 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to

17 depositions that reveal Protected Material may be separately bound by the court reporter

18 and may not be disclosed to anyone except as permitted under this Stipulated Protective

19 Order; and

20 (i) any mediator or settlement officer, and their supporting personnel, mutually

21 agreed upon by any of the parties engaged in settlement discussions.

22 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

23 ONLY” Information or Items. Unless otherwise ordered by the Court or permitted in

24 writing by the Designating Party, a Receiving Party may disclose “HIGHLY

25 CONFIDENTIAL - ATTORNEYS’ EYES ONLY” Information or Items only to those

26 individuals listed above in Paragraphs 7.2(a), (c)–(g), and (i), except that a Receiving

27 Party may in good faith request that the Designating Party consent in writing to the 28 disclosure of particular material designated “HIGHLY CONFIDENTIAL - 1 ATTORNEYS’ EYES ONLY” to one or more representatives of the Receiving Party to

2 whom disclosure is reasonably necessary for this Action. The Receiving Party may seek

3 leave of court to designate such representatives if the Receiving Party believes that the

4 Designating Party has unreasonably withheld such consent. Before receiving any

5 “HIGHLY CONFIDENTIAL - ATTORNEYS’ EY ES ONLY” Information or Items,

6 each designated representative shall sign the “Acknowledgment and Agreement to Be

7 Bound” (Exhibit A).

8

9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

10 IN OTHER LITIGATION

11 If a Party is served with a subpoena or a court order issued in other litigation that

12 compels disclosure of any information or items designated in this Action as

13 “CONFIDENTIAL,” that Party must:

14 (a) promptly notify in writing the Designating Party. Such notification shall

15 include a copy of the subpoena or court order;

16 (b) promptly notify in writing the party who caused the subpoena or order to issue

17 in the other litigation that some or all of the material covered by the subpoena or order is

18 subject to this Protective Order. Such notification shall include a copy of this Stipulated

19 Protective Order; and

20 (c) cooperate with respect to all reasonable procedures sought to be pursued by

21 the Designating Party whose Protected Material may be affected.

22 If the Designating Party timely seeks a protective order, the Party served with the

23 subpoena or court order shall not produce any information designated in this action as

24 “CONFIDENTIAL” before a determination by the court from which the subpoena or

25 order issued, unless the Party has obtained the Designating Party’s permission. The

26 Designating Party shall bear the burden and expense of seeking protection in that court

27 of its confidential material and nothing in these provisions should be construed as 28 1 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

2 directive from another court.

3

4 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

5 PRODUCED IN THIS LITIGATION

6 (a) The terms of this Order are applicable to information produced by a Non-Party

7 in this Action and designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –

8 ATTORNEYS’ EYES ONLY.” Such information produced by Non-Parties in

9 connection with this litigation is protected by the remedies and relief provided by this

10 Order. Nothing in these provisions should be construed as prohibiting a Non-Party from

11 seeking additional protections.

12 (b) In the event that a Party is required, by a valid discovery request, to produce a

13 Non-Party’s confidential information in its possession, and the Party is subject to an

14 agreement with the Non-Party not to produce the Non-Party’s confidential information,

15 then the Party shall:

16 (1) promptly notify in writing the Requesting Party and the Non-Party that

17 some or all of the information requested is subject to a confidentiality agreement

18 with a Non-Party;

19 (2) promptly provide the Non-Party with a copy of the Stipulated

20 Protective Order in this Action, the relevant discovery request(s), and a

21 reasonably specific description of the information requested; and

22 (3) make the information requested available for inspection by the Non-

23 Party, if requested.

24 (c) If the Non-Party fails to seek a protective order from this court within 14 days

25 of receiving the notice and accompanying information, the Receiving Party may

26 produce the Non-Party’s confidential information responsive to the discovery request. If

27 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 28 information in its possession or control that is subject to the confidentiality agreement 1 with the Non-Party before a determination by the court. Absent a court order to the

2 contrary, the Non-Party shall bear the burden and expense of seeking protection in this

3 court of its Protected Material.

4

5 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

6 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

7 Protected Material to any person or in any circumstance not authorized under this

8 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing

9 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

10 all unauthorized copies of the Protected Material, (c) inform the person or persons to

11 whom unauthorized disclosures were made of all the terms of this Order, and (d) request

12 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”

13 that is attached hereto as Exhibit A.

14

15 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

16 PROTECTED MATERIAL

17 When a Producing Party gives notice to Receiving Parties that certain

18 inadvertently produced material is subject to a claim of privilege or other protection, the

19 obligations of the Receiving Parties are those set forth in Federal Rule of Civil

20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

21 may be established in an e-discovery order that provides for production without prior

22 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

23 parties reach an agreement on the effect of disclosure of a communication or

24 information covered by the attorney-client privilege or work product protection, the

25 parties may incorporate their agreement in the stipulated protective order submitted to

26 the court.

27 12. MISCELLANEOUS 28 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 1 person to seek its modification by the Court in the future.

2 12.2 Right to Assert Other Objections. By stipulating to the entry of this

3 Protective Order no Party waives any right it otherwise would have to object to

4 disclosing or producing any information or item on any ground not addressed in this

5 Stipulated Protective Order. Similarly, no Party w aives any right to object on any

6 ground to use in evidence of any of the material covered by this Protective Order.

7 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected

8 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed

9 under seal pursuant to a court order authorizing the sealing of the specific Protected

10 Material at issue. If a Party's request to file Protected Material under seal is denied by

11 the court, then the Receiving Party may file the information in the public record unless

12 otherwise instructed by the court.

13

14 13. FINAL DISPOSITION

15 After the final disposition of this Action, as defined in paragraph 4, within 60

16 days of a written request by the Designating Party, each Receiving Party must return all

17 Protected Material to the Producing Party or destroy such material. As used in this

18 subdivision, “all Protected Material” includes all copies, abstracts, compilations,

19 summaries, and any other format reproducing or capturing any of the Protected

20 Material. Whether the Protected Material is returned or destroyed, the Receiving Party

21 must submit a written certification to the Producing Party (and, if not the same person or

22 entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category,

23 where appropriate) all the Protected Material that was returned or destroyed and

24 (2)affirms that the Receiving Party has not retained any copies, abstracts, compilations,

25 summaries or any other format reproducing or capturing any of the Protected Material.

26 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all

27 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 28 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 1 | consultant and expert work product, even if such materials contain Protected Material. 2 | Any such archival copies that contain or constitute Protected Material remain subject to 3 | this Protective Order as set forth in Section 4 (DURATION). 4 14. Any violation of this Order may be punished by any and all appropriate 5|measures including, without limitation, contempt proceedings and/or monetary 6 | sanctions. 7 8 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 9 10 | DATED May 7, 2021 11 | EPSTEIN DRANGEL LLP 12 /s/Peter J. Farnese 13 | Peter J. Farnese 14 | Attorneys for Plaintiff and Counterclaim-Defendant Happy Ashley Ltd. 15 16 | DATED: May 7, 2021 17] BRUTZKUS GUBNER 18 /s/Michael A. Bernet 19 | Michael A. Bernet 20 | Attorneys for Defendant and Counterclaim-Plaintiff All Access Apparel, Inc. 21 22 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23 24|DATED: May 7, 2021 25 so 97 | Honorable Steve Kim United States Magistrate Judge 28 _14_

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], de clare under penalty of perjury that I have read in its entirety and understand the Stipulated Protective Order that was issued 6 by the United States District Court for the Central District of California on [date] in the 7 case of Happy Ashley Ltd. v. All Access Apparel, Inc., Case No. 2:20-cv-9702-DMG-

8 SK. I agree to comply with and to be bound by all the terms of this Stipulated Protective Order and I understand and acknowledge that failure to so comply could expose me to 9 sanctions and punishment in the nature of contempt. I solemnly promise that I will not 10 disclose in any manner any information or item that is subject to this Stipulated

11 Protective Order to any person or entity except in strict compliance with the provisions

of this Order. 12 I further agree to submit to the jurisdiction of the United States District Court for the 13 Central District of California for the purpose of enforcing the terms of this Stipulated

14 Protective Order, even if such enforcement proceedings occur after termination of this

15 action. I hereby appoint __________________________ [print or type full name] of _______________________________________ [print or type full address and 16 telephone number] as my California agent for service of process in connection with this 17 action or any proceedings related to enforcement of this Stipulated Protective Order.

18 Date: ______________________________________ City and State where sworn and signed: _________________________________ 19

20 Printed name: _______________________________

21

Signature: __________________________________ 22

23

24

25

26

27 28