1 Allison C. Eckstrom, California Bar No. 217255 [email protected] 2 Christopher J. Archibald, California Bar No. 253075 [email protected] 3 BRYAN CAVE LEIGHTON PAISNER LLP 4 1920 Main Street, Suite 1000 Irvine, California 92612-4414 5 Telephone: (949) 223-7000 NOTE: CHANGES MADE BY THE COURT Facsimile: (949) 223-7100 6

7 Attorneys for Defendant OLD DOMINION FREIGHT LINE, INC. 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 11

12 ADAM WATSON, an individual, Case No. 2:20-CV-08018-JWH (JPRx)

13 Plaintiff, Hon. John W. Holcomb

14 vs. STIPULATED PROTECTIVE 15 ORDER OLD DOMINION FREIGHT LINE, 16 INC., a Virginia corporation; and DOES 1 through 10, inclusive, 17

18 Defendants.

19 20 21 22 23 24 25 26 27 28 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 6 following Stipulated Protective Order. The parties acknowledge that this Order does 7 not confer blanket protections on all disclosures or responses to discovery and that 8 the protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable 10 legal principles. 11 B. GOOD CAUSE STATEMENT 12 This action is likely to involve trade secrets, customer and pricing lists and 13 other valuable research, development, commercial, financial, technical and/or 14 proprietary information for which special protection from public disclosure and from 15 use for any purpose other than prosecution of this action may be warranted. Such 16 confidential and proprietary materials and information may consist of, among other 17 things, confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, development, or 19 commercial information (including information implicating privacy rights of third 20 parties), information otherwise generally unavailable to the public, or which may be 21 privileged or otherwise protected from disclosure under state or federal statutes, court 22 rules, case decisions, or common law. Accordingly, to expedite the flow of 23 information, to facilitate the prompt resolution of disputes over confidentiality of 24 discovery materials, to adequately protect information the parties are entitled to keep 25 confidential, to ensure that the parties are permitted reasonable necessary uses of such 26 material in preparation for and in the conduct of trial, to address their handling at the 27 end of the litigation, and serve the ends of justice, a protective order for such 28 1 information is justified in this matter. It is the intent of the parties that information 2 will not be designated as confidential for tactical reasons and that nothing be so 3 designated without a good faith belief that it has been maintained in a confidential, 4 non-public manner, and there is good cause why it should not be part of the public 5 record of this case. 6 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 7 SEAL 8 The parties further acknowledge, as set forth in Section 12.3, below, that this 9 Stipulated Protective Order does not entitle them to file confidential information 10 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 11 the standards that will be applied when a party seeks permission from the court to file 12 material under seal. 13 There is a strong presumption that the public has a right of access to judicial 14 proceedings and records in civil cases. In connection with non-dispositive motions, 15 good cause must be shown to support a filing under seal. See Kamakana v. City and 16 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 17 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 18

(E.D. Wis. 1999) (even stipulated protective orders require good 19 cause showing), and a specific showing of good cause or compelling reasons with 20 proper evidentiary support and legal justification, must be made with respect to 21 Protected Material that a party seeks to file under seal. The parties’ mere designation 22 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the 23 submission of competent evidence by declaration, establishing that the material 24 sought to be filed under seal qualifies as confidential, privileged, or otherwise 25 protectable—constitute good cause. 26 Further, if a party requests sealing related to a dispositive motion or trial, then 27 compelling reasons, not only good cause, for the sealing must be shown, and the 28 relief sought shall be narrowly tailored to serve the specific interest to be protected. 1 See Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For 2 each item or type of information, document, or thing sought to be filed or introduced 3 under seal in connection with a dispositive motion or trial, the party seeking 4 protection must articulate compelling reasons, supported by specific facts and legal 5 justification, for the requested sealing order. Again, competent evidence supporting 6 the application to file documents under seal must be provided by declaration. 7 Any document that is not confidential, privileged, or otherwise protectable in 8 its entirety will not be filed under seal if the confidential portions can be redacted. If 9 documents can be redacted, then a redacted version for public viewing, omitting 10 only the confidential, privileged, or otherwise protectable portions of the document, 11 shall be filed. Any application that seeks to file documents under seal in their 12 entirety should include an explanation of why redaction is not feasible. 13 2. DEFINITIONS 14 2.1 Action: Adam Watson v. Old Dominion Freight Line, Inc.; Case 15 No. 2:20-CV-08018-JWH (JPRx). 16 2.2 Challenging Party: a Party or Non-Party that challenges the 17 designation of information or items under this Order. 18 2.3 “CONFIDENTIAL” Information or Items: information 19 (regardless of how it is generated, stored or maintained) or 20 tangible things that qualify for protection under Federal Rule of 21 Civil Procedure 26(c), and as specified above in the Good Cause 22 Statement. 23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well 24 as their support staff). 25 2.5 Designating Party: a Party or Non-Party that designates 26 information or items that it produces in disclosures or in responses 27 to discovery as “CONFIDENTIAL.” 28 1 2.6 Disclosure or Discovery Material: all items or information, 2 regardless of the medium or manner in which it is generated, 3 stored, or maintained (including, among other things, testimony, 4 transcripts, and tangible things), that are produced or generated in 5 disclosures or responses to discovery in this matter. 6 2.7 Expert: a person with specialized knowledge or experience in a 7 matter pertinent to the litigation who has been retained by a Party 8 or its counsel to serve as an expert witness or as a consultant in 9 this Action. 10 2.8 House Counsel: attorneys who are employees of a party to this 11 Action. House Counsel does not include Outside Counsel of 12 Record or any other outside counsel. 13 2.9 Non-Party: any natural person, partnership, corporation, 14 association or other legal entity not named as a Party to this action. 15 2.10 Outside Counsel of Record: attorneys who are not employees of a 16 party to this Action but are retained to represent or advise a party 17 to this Action and have appeared in this Action on behalf of that 18 party or are affiliated with a law firm that has appeared on behalf 19 of that party, and includes support staff. 20 2.11 Party: any party to this Action, including all of its officers, 21 directors, employees, consultants, retained experts, and Outside 22 Counsel of Record (and their support staffs). 23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 24 Discovery Material in this Action. 25 2.13 Professional Vendors: persons or entities that provide litigation 26 support services (e.g., photocopying, videotaping, translating, 27 preparing exhibits or demonstrations, and organizing, storing, or 28 1 retrieving data in any form or medium) and their employees and 2 subcontractors. 3 2.14 Protected Material: any Disclosure or Discovery Material that is 4 designated as “CONFIDENTIAL.” 5 2.15 Receiving Party: a Party that receives Disclosure or Discovery 6 Material from a Producing Party. 7 3. SCOPE 8 The protections conferred by this Stipulation and Order cover not only 9 Protected Material (as defined above), but also (1) any information copied or extracted 10 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 11 Protected Material; and (3) any testimony, conversations, or presentations by Parties 12 or their Counsel that might reveal Protected Material. 13 Any use of Protected Material at trial shall be governed by the orders of the 14 trial judge. This Order does not govern the use of Protected Material at trial. 15 4. DURATION 16 Once a case proceeds to trial, information that was designated as 17 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 18 as an exhibit at trial becomes public and will be presumptively available to all 19 members of the public, including the press, unless compelling reasons supported by 20 specific factual findings to proceed otherwise are made to the trial judge in advance 21 of the trial. See Kamakana,

(distinguishing “good cause” 22 showing for sealing documents produced in discovery from “compelling reasons” 23 standard when merits-related documents are part of court record). Accordingly, the 24 terms of this protective order do not extend beyond the commencement of the trial. 25 5. DESIGNATING PROTECTED MATERIAL 26 5.1 Exercise of Restraint and Care in Designating Material for 27 Protection. Each Party or Non-Party that designates information 28 or items for protection under this Order must take care to limit any 1 such designation to specific material that qualifies under the 2 appropriate standards. The Designating Party must designate for 3 protection only those parts of material, documents, items or oral 4 or written communications that qualify so that other portions of 5 the material, documents, items or communications for which 6 protection is not warranted are not swept unjustifiably within the 7 ambit of this Order. 8 Mass, indiscriminate or routinized designations are prohibited. Designations 9 that are shown to be clearly unjustified or that have been made for an improper 10 purpose (e.g., to unnecessarily encumber the case development process or to impose 11 unnecessary expenses and burdens on other parties) may expose the Designating Party 12 to sanctions. 13 If it comes to a Designating Party’s attention that information or items that it 14 designated for protection do not qualify for protection, that Designating Party must 15 promptly notify all other Parties that it is withdrawing the inapplicable designation. 16 5.2 Manner and Timing of Designations. Except as otherwise 17 provided in this Order (see, e.g., second paragraph of section 18 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 19 Discovery Material that qualifies for protection under this Order 20 must be clearly so designated before the material is disclosed or 21 produced. 22 Designation in conformity with this Order requires: 23 (a) for information in documentary form (e.g., paper or 24 electronic documents, but excluding transcripts of 25 depositions or other pretrial or trial proceedings), that the 26 Producing Party affix at a minimum, the legend 27 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL 28 legend”), to each page that contains protected material. If 1 only a portion of the material on a page qualifies for 2 protection, the Producing Party also must clearly identify 3 the protected portion(s) (e.g., by making appropriate 4 markings in the margins). 5 A Party or Non-Party that makes original documents available for inspection 6 need not designate them for protection until after the inspecting Party has indicated 7 which documents it would like copied and produced. During the inspection and before 8 the designation, all of the material made available for inspection shall be deemed 9 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 10 copied and produced, the Producing Party must determine which documents, or 11 portions thereof, qualify for protection under this Order. Then, before producing the 12 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 13 to each page that contains Protected Material. If only a portion of the material on a 14 page qualifies for protection, the Producing Party also must clearly identify the 15 protected portion(s) (e.g., by making appropriate markings in the margins). 16 (b) for testimony given in depositions that the Designating 17 Party identifies the Disclosure or Discovery Material on the 18 record, before the close of the deposition all protected 19 testimony. 20 (c) for information produced in some form other than 21 documentary and for any other tangible items, that the 22 Producing Party affix in a prominent place on the exterior 23 of the container or containers in which the information is 24 stored the legend “CONFIDENTIAL.” If only a portion or 25 portions of the information warrants protection, the 26 Producing Party, to the extent practicable, shall identify the 27 protected portion(s). 28 1 5.3 Inadvertent Failures to Designate. If timely corrected, an 2 inadvertent failure to designate qualified information or items 3 does not, standing alone, waive the Designating Party’s right to 4 secure protection under this Order for such material. Upon timely 5 correction of a designation, the Receiving Party must make 6 reasonable efforts to assure that the material is treated in 7 accordance with the provisions of this Order. 8 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 9 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 10 designation of confidentiality at any time that is consistent with 11 the Court’s Scheduling Order. 12 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 13 resolution process under Local Rule 37-1 et seq. 14 6.3 Joint Stipulation. Any challenge submitted to the Court shall be 15 via a joint stipulation pursuant to Local Rule 37-2. 16 The burden of persuasion in any such challenge proceeding shall be on 17 the Designating Party. Frivolous challenges, and those made for an improper purpose 18 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 19 expose the Challenging Party to sanctions. Unless the Designating Party has waived 20 or withdrawn the confidentiality designation, all parties shall continue to afford the 21 material in question the level of protection to which it is entitled under the Producing 22 Party’s designation until the Court rules on the challenge. 23 7. ACCESS TO AND USE OF PROTECTED MATERIAL 24 7.1 Basic Principles. A Receiving Party may use Protected Material 25 that is disclosed or produced by another Party or by a Non-Party 26 in connection with this Action only for prosecuting, defending or 27 attempting to settle this Action. Such Protected Material may be 28 disclosed only to the categories of persons and under the 1 conditions described in this Order. When the Action has been 2 terminated, a Receiving Party must comply with the provisions of 3 section 13 below (FINAL DISPOSITION). 4 Protected Material must be stored and maintained by a Receiving Party at a 5 location and in a secure manner that ensures that access is limited to the persons 6 authorized under this Order. 7 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 8 otherwise ordered by the court or permitted in writing by the 9 Designating Party, a Receiving Party may disclose any 10 information or item designated “CONFIDENTIAL” only to: 11 (a) the Receiving Party’s Outside Counsel of Record in this 12 Action, as well as employees of said Outside Counsel of 13 Record to whom it is reasonably necessary to disclose the 14 information for this Action; 15 (b) the officers, directors, and employees (including House 16 Counsel) of the Receiving Party to whom disclosure is 17 reasonably necessary for this Action; 18 (c) Experts (as defined in this Order) of the Receiving Party to 19 whom disclosure is reasonably necessary for this Action 20 and who have signed the “Acknowledgment and Agreement 21 to Be Bound” (Exhibit A); 22 (d) the court and its personnel; 23 (e) court reporters and their staff; 24 (f) professional jury or trial consultants, mock jurors, and 25 Professional Vendors to whom disclosure is reasonably 26 necessary for this Action and who have signed the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit 28 A); 1 (g) the author or recipient of a document containing the 2 information or a custodian or other person who otherwise 3 possessed or knew the information; 4 (h) during their depositions, witnesses, and attorneys for 5 witnesses, in the Action to whom disclosure is reasonably 6 necessary provided: (1) the deposing party requests that the 7 witness sign the form attached as Exhibit A hereto; and (2) 8 they will not be permitted to keep any confidential 9 information unless they sign the “Acknowledgment and 10 Agreement to Be Bound” (Exhibit A), unless otherwise 11 agreed by the Designating Party or ordered by the court. 12 Pages of transcribed deposition testimony or exhibits to 13 depositions that reveal Protected Material may be 14 separately bound by the court reporter and may not be 15 disclosed to anyone except as permitted under this 16 Stipulated Protective Order; and 17 (i) any mediator or settlement officer, and their supporting 18 personnel, mutually agreed upon by any of the parties 19 engaged in settlement discussions or appointed by the 20 Court. 21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 22 IN OTHER LITIGATION 23 If a Party is served with a subpoena or a court order issued in other litigation 24 that compels disclosure of any information or items designated in this Action as 25 “CONFIDENTIAL,” that Party must: 26 (a) promptly notify in writing the Designating Party. Such 27 notification shall include a copy of the subpoena or court 28 order unless prohibited by law; 1 (b) promptly notify in writing the party who caused the 2 subpoena or order to issue in the other litigation that some 3 or all of the material covered by the subpoena or order is 4 subject to this Protective Order. Such notification shall 5 include a copy of this Stipulated Protective Order; and 6 (c) cooperate with respect to all reasonable procedures sought 7 to be pursued by the Designating Party whose Protected 8 Material may be affected. 9 If the Designating Party timely seeks a protective order, the Party served with 10 the subpoena or court order shall not produce any information designated in this action 11 as “CONFIDENTIAL” before a determination by the court from which the subpoena 12 or order issued, unless the Party has obtained the Designating Party’s permission. The 13 Designating Party shall bear the burden and expense of seeking protection in that court 14 of its confidential material and nothing in these provisions should be construed as 15 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 16 directive from another court. 17 9. 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 20 produced by a Non-Party in this Action and designated as 21 “CONFIDENTIAL.” Such information produced by Non- 22 Parties in connection with this litigation is protected by the 23 remedies and relief provided by this Order. Nothing in these 24 provisions should be construed as prohibiting a Non-Party 25 from seeking additional protections. 26 (b) In the event that a Party is required, by a valid discovery 27 request, to produce a Non-Party’s confidential information 28 in its possession, and the Party is subject to an agreement 1 with the Non-Party not to produce the Non-Party’s 2 confidential information, then the Party shall: 3 (1) promptly notify in writing the Requesting Party and 4 the Non-Party that some or all of the information 5 requested is subject to a confidentiality agreement 6 with a Non-Party; 7 (2) promptly provide the Non-Party with a copy of the 8 Stipulated Protective Order in this Action, the 9 relevant discovery request(s), and a reasonably 10 specific description of the information requested; 11 and 12 (3) make the information requested available for 13 inspection by the Non-Party, if requested. 14 (c) If the Non-Party fails to seek a protective order from this 15 court within 14 days of receiving the notice and 16 accompanying information, the Receiving Party may 17 produce the Non-Party’s confidential information 18 responsive to the discovery request. If the Non-Party timely 19 seeks a protective order, the Receiving Party shall not 20 produce any information in its possession or control that is 21 subject to the confidentiality agreement with the Non-Party 22 before a determination by the court. Absent a court order to 23 the contrary, the Non-Party shall bear the burden and 24 expense of seeking protection in this court of its Protected 25 Material. 26 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 27 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 28 Protected Material to any person or in any circumstance not authorized under this 1 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 2 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 3 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 4 persons to whom unauthorized disclosures were made of all the terms of this Order, 5 and (d) request such person or persons to execute the “Acknowledgment and 6 Agreement to Be Bound” that is attached hereto as Exhibit A. 7 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 8 PROTECTED MATERIAL 9 When a Producing Party gives notice to Receiving Parties that certain 10 inadvertently produced material is subject to a claim of privilege or other protection, 11 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 12 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 13 may be established in an e-discovery order that provides for production without prior 14 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 15 parties reach an agreement on the effect of disclosure of a communication or 16 information covered by the attorney-client privilege or work product protection, the 17 parties may incorporate their agreement in the stipulated protective order submitted 18 to the court provided the Court so allows. 19 12. MISCELLANEOUS 20 12.1 Right to Further Relief. Nothing in this Order abridges the right of 21 any person to seek its modification by the Court in the future. 22 12.2 Right to Assert Other Objections. By stipulating to the entry of 23 this Protective Order, no Party waives any right it otherwise would 24 have to object to disclosing or producing any information or item 25 on any ground not addressed in this Stipulated Protective Order. 26 Similarly, no Party waives any right to object on any ground to 27 use in evidence of any of the material covered by this Protective 28 Order. 1 12.3 Filing Protected Material. A Party that seeks to file under seal any 2 Protected Material must comply with Local Civil Rule 79-5. 3 Protected Material may only be filed under seal pursuant to a court 4 order authorizing the sealing of the specific Protected Material at 5 issue. If a Party’s request to file Protected Material under seal is 6 denied by the court, then the Receiving Party may file the 7 information in the public record unless otherwise instructed by the 8 court. 9 13. FINAL DISPOSITION 10 After the final disposition of this Action, as defined in paragraph 4, within 60 11 days of a written request by the Designating Party, each Receiving Party must return 12 all Protected Material to the Producing Party or destroy such material. As used in this 13 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 14 summaries, and any other format reproducing or capturing any of the Protected 15 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 16 must submit a written certification to the Producing Party (and, if not the same person 17 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 18 category, where appropriate) all the Protected Material that was returned or destroyed 19 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 20 compilations, summaries or any other format reproducing or capturing any of the 21 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 22 archival copy of all pleadings, motion papers, trial, deposition, and hearing 23 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 24 reports, attorney work product, and consultant and expert work product, even if such 25 materials contain Protected Material. Any such archival copies that contain or 26 constitute Protected Material remain subject to this Protective Order as set forth in 27 Section 4 (DURATION). Notwithstanding the foregoing, a Party is not required to 28 delete/destroy/return confidential information that is otherwise subject to an existing 1 record retention schedule that provides for deletion/destruction of the Confidential 2 Information. 3 14. VIOLATION 4 Any violation of this Order may be punished by appropriate measures 5 including, without limitation, contempt proceedings and/or monetary sanctions. 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 ***The filer of this document hereby attests that concurrence in the filing of 8 this document has been obtained from the other signatories hereto.*** 9 10 11 Dated: July 28, 2021 Allison C. Eckstrom 12 Christopher J. Archibald 13 BRYAN CAVE LEIGHTON PAISNER LLP

14 By: /s/ Christopher J. Archibald 15 Christopher J. Archibald Attorneys for Defendant 16 OLD DOMINION FREIGHT LINE, INC. 17

18 Dated: July 28, 2021 Ji-In Lee Houck David Angeloff 19 Cindy Hickox 20 STALWART LAW GROUP, APC

21 By: /s/ Cindy Hickox 22 Cindy Hickox 23 Attorneys for Plaintiff ADAM WATSON 24

25

26 27 28 , | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 fe RrewMutl~ 3 DATED: August 2, 2021 Hon. Jean P. Rosenbluth 4 United States Magistrate Judge 5 6 7 8 9 10 11

12

x 13 9 35 14 < 15 = 16

18 19 20 21 22 23 24 25 26 27 28 USA.603955469.1/ZAA 17

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of [print 4 or type full address], declare under penalty of perjury that I have read in its entirety 5 and understand the Stipulated Protective Order that was issued by the United States 6 District Court for the Central District of California on [date] in the case of Adam 7 Watson v. Old Dominion Freight Line, Inc.; Case No. 2:20-CV-08018-JWH (JPRx). 8 I agree to comply with and to be bound by all the terms of this Stipulated Protective 9 Order and I understand and acknowledge that failure to so comply could expose me 10 to sanctions and punishment in the nature of contempt. I solemnly promise that I will 11 not disclose in any manner any information or item that is subject to this Stipulated 12 Protective Order to any person or entity except in strict compliance with the 13 provisions of this Order. I further agree to submit to the jurisdiction of the United 14 States District Court for the Central District of California for enforcing the terms of 15 this Stipulated Protective Order, even if such enforcement proceedings occur after 16 termination of this action. I hereby appoint ________________________________ 17 [print or type full name] of __________________________________ [print or type 18 full address and telephone number] as my California agent for service of process in 19 connection with this action or any proceedings related to enforcement of this 20 Stipulated Protective Order. 21 Date:_________________________________________________ 22 City and State where sworn and 23 signed:_________________________________________ 24 25 Printed name:__________________________________________ 26 27 Signature:_____________________________________________ 28