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6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 SOUTHERN DIVISION 11 Case No. 8:20-cv-01756-JLS-ADS 12 WILLIAM ALLEN, 13 STIPULATED PROTECTIVE Plaintiff, 14 ORDER v. 15 [Discovery Document; Referred to FRANK KENDALL III, in his official Magistrate Judge Autumn D. Spaeth] 16 capacity as Secretary, Department of the Air Force, 17 Defendant. 18 19 20 21 22 23 24 1 I. PURPOSES AND LIMITATIONS 2 A. Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation 5 may be warranted. Accordingly, the parties hereby stipulate to and petition the

6 Court to enter the following Stipulated Protective Order. The parties 7 acknowledge that this Order does not confer blanket protections on all 8 disclosures or responses to discovery and that the protection it affords from 9 public disclosure and use extends only to the limited information or items that 10 are entitled to confidential treatment under the applicable legal principles. The 11 parties further acknowledge, as set forth in Section XIII(C), below, that this 12 Stipulated Protective Order does not entitle them to file confidential information 13 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed 14 and the standards that will be applied when a party seeks permission from the 15 Court to file material under seal. 16 II. GOOD CAUSE STATEMENT

17 A. This action is likely to involve private personal information of Plaintiff 18 and third-party employees of Defendant, as well as third-party patients for 19 which special protection from public disclosure and from use for any purpose 20 other than prosecution of this action is warranted. Such confidential and 21 proprietary materials and information consist of, among other things, medical 22 records, personnel records, and personal information of third-party employees 23 of Defendant, and information otherwise generally unavailable to the public, or 24 which may be privileged or otherwise protected from disclosure under state or 1 federal statutes, court rules, case decisions, or common law. Accordingly, to 2 expedite the flow of information, to facilitate the prompt resolution of disputes 3 over confidentiality of discovery materials, to adequately protect information the 4 parties are entitled to keep confidential, to adequately protect against 5 inadvertent disclosure of privileged information or otherwise protected from

6 disclosure, to ensure that the parties are permitted reasonable necessary uses of 7 such material in preparation for and in the conduct of trial, to address their 8 handling at the end of the litigation, and serve the ends of justice, a protective 9 order for such information is justified in this matter. It is the intent of the 10 parties that information will not be designated as confidential for tactical 11 reasons and that nothing be so designated without a good faith belief that it has 12 been maintained in a confidential, non-public manner, and there is good cause 13 why it should not be part of the public record of this case. 14 III. DEFINITIONS 15 A. Action: William Allen v. Frank Kendall III, Case No. 8:20-cv-01756-JLS- 16 ADS.

17 B. Challenging Party: A Party or Non-Party that challenges the designation 18 of information or items under this Order. 19 C. “CONFIDENTIAL” Information or Items: Information (regardless of how 20 it is generated, stored or maintained) or tangible things that qualify for 21 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 22 the Good Cause Statement. 23 D. Counsel: Outside Counsel of Record and House Counsel (as well as their 24 support staff). 1 E. Designating Party: A Party or Non-Party that designates information or 2 items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 F. Disclosure or Discovery Material: All items or information, regardless of 5 the medium or manner in which it is generated, stored, or maintained

6 (including, among other things, testimony, transcripts, and tangible things), that 7 are produced or generated in disclosures or responses to discovery in this 8 matter. 9 G. Expert: A person with specialized knowledge or experience in a matter 10 pertinent to the litigation who has been retained by a Party or its counsel to 11 serve as an expert witness or as a consultant in this Action. 12 H. House Counsel: Attorneys who are employees of a party to this Action. 13 House Counsel does not include Outside Counsel of Record or any other outside 14 counsel. 15 I. Non-Party: Any natural person, partnership, corporation, association, or 16 other legal entity not named as a Party to this action.

17 J. Outside Counsel of Record: Attorneys who are not employees of a party 18 to this Action but are retained to represent or advise a party to this Action and 19 have appeared in this Action on behalf of that party or are affiliated with a law 20 firm which has appeared on behalf of that party, and includes support staff. 21 K. Party: Any party to this Action, including all of its officers, directors, 22 employees, consultants, retained experts, and Outside Counsel of Record (and 23 their support staffs). 24 1 L. Producing Party: A Party or Non-Party that produces Disclosure or 2 Discovery Material in this Action. 3 M. Professional Vendors: Persons or entities that provide litigation support 4 services (e.g., photocopying, videotaping, translating, preparing exhibits or 5 demonstrations, and organizing, storing, or retrieving data in any form or

6 medium) and their employees and subcontractors. 7 N. Protected Material: Any Disclosure or Discovery Material that is 8 designated as “CONFIDENTIAL.” 9 O. Receiving Party: A Party that receives Disclosure or Discovery Material 10 from a Producing Party. 11 IV. SCOPE 12 A. The protections conferred by this Stipulation and Order cover not only 13 Protected Material (as defined above), but also (1) any information copied or 14 extracted from Protected Material; (2) all copies, excerpts, summaries, or 15 compilations of Protected Material; and (3) any testimony, conversations, or 16 presentations by Parties or their Counsel that might reveal Protected Material.

17 B. Any use of Protected Material at trial shall be governed by the orders of 18 the trial judge. This Order does not govern the use of Protected Material at trial. 19 V. DURATION 20 A. Once a case proceeds to trial, all of the information that was designated as 21 confidential or maintained pursuant to this Protective Order becomes public and 22 will be presumptively available to all members of the public, including the press, 23 unless compelling reasons supported by specific factual findings to proceed 24 otherwise are made to the trial judge in advance of the trial. See Kamakana v. 1 City and County of Honolulu,

(9th Cir. 2006) 2 (distinguishing “good cause” showing for sealing documents produced in 3 discovery from “compelling reasons” standard when merits-related documents 4 are part of court record). Accordingly, the terms of this Protective Order do not 5 extend beyond the commencement of the trial.

6 VI. DESIGNATING PROTECTED MATERIAL 7 A. Exercise of Restraint and Care in Designating Material for Protection 8 1. Each Party or Non-Party that designates information or items for 9 protection under this Order must take care to limit any such designation 10 to specific material that qualifies under the appropriate standards. The 11 Designating Party must designate for protection only those parts of 12 material, documents, items, or oral or written communications that 13 qualify so that other portions of the material, documents, items, or 14 communications for which protection is not warranted are not swept 15 unjustifiably within the ambit of this Order. 16 2. Mass, indiscriminate, or routinized designations are prohibited.

17 Designations that are shown to be clearly unjustified or that have been 18 made for an improper purpose (e.g., to unnecessarily encumber the case 19 development process or to impose unnecessary expenses and burdens on 20 other parties) may expose the Designating Party to sanctions. 21 3. If it comes to a Designating Party’s attention that information or 22 items that it designated for protection do not qualify for protection, that 23 Designating Party must promptly notify all other Parties that it is 24 withdrawing the inapplicable designation. 1 B. Manner and Timing of Designations 2 1. Except as otherwise provided in this Order (see, e.g., Section 3 B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or 4 Discovery Material that qualifies for protection under this Order must be 5 clearly so designated before the material is disclosed or produced.

6 2. Designation in conformity with this Order requires the following: 7 a. For information in documentary form (e.g., paper or 8 electronic documents, but excluding transcripts of depositions or 9 other pretrial or trial proceedings), that the Producing Party affix 10 at a minimum, the legend “CONFIDENTIAL” (hereinafter 11 “CONFIDENTIAL legend”), to each page that contains protected 12 material. If only a portion or portions of the material on a page 13 qualifies for protection, the Producing Party also must clearly 14 identify the protected portion(s) (e.g., by making appropriate 15 markings in the margins). As stated in the parties’ joint Rule 26(f) 16 Report (ECF No. 22), the parties agree that each electronically

17 stored document shall be produced as a separate, Bates-stamped 18 PDF. The parties agree that electronic documents may be 19 produced in native format in cases where conversion to PDF is not 20 practicable (e.g., Excel files). To the extent any documents are 21 produced in native electronic format, such documents will not have 22 a physical legend. Any documents produced in native electronic 23 format that are designated “CONFIDENTIAL” shall be prepended 24 with “CONFIDENTIAL” and the Bates number or Bates range in 1 the filename. In the event the Receiving Party prints any native 2 electronic document or file designated “CONFIDENTIAL,” it shall 3 be the responsibility of the Receiving Party to affix the appropriate 4 “CONFIDENTIAL” legend and Bates stamp to the printed 5 document or file before disclosing to persons authorized under this

6 Order. 7 b. A Party or Non-Party that makes original documents 8 available for inspection need not designate them for protection 9 until after the inspecting Party has indicated which documents it 10 would like copied and produced. During the inspection and before 11 the designation, all of the material made available for inspection 12 shall be deemed “CONFIDENTIAL.” After the inspecting Party has 13 identified the documents it wants copied and produced, the 14 Producing Party must determine which documents, or portions 15 thereof, qualify for protection under this Order. Then, before 16 producing the specified documents, the Producing Party must affix

17 the “CONFIDENTIAL legend” to each page that contains Protected 18 Material. If only a portion or portions of the material on a page 19 qualifies for protection, the Producing Party also must clearly 20 identify the protected portion(s) (e.g., by making appropriate 21 markings in the margins). 22 c. For testimony given in depositions, that the Designating 23 Party identify the Disclosure or Discovery Material on the record, 24 before the close of the deposition all protected testimony. 1 d. For information produced in form other than document and 2 for any other tangible items, that the Producing Party affix in a 3 prominent place on the exterior of the container or containers in 4 which the information is stored the legend “CONFIDENTIAL.” If 5 only a portion or portions of the information warrants protection,

6 the Producing Party, to the extent practicable, shall identify the 7 protected portion(s). 8 C. Inadvertent Failure to Designate 9 1. If timely corrected, an inadvertent failure to designate qualified 10 information or items does not, standing alone, waive the Designating 11 Party’s right to secure protection under this Order for such material. 12 Upon timely correction of a designation, the Receiving Party must make 13 reasonable efforts to assure that the material is treated in accordance with 14 the provisions of this Order. 15 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 16 A. Timing of Challenges

17 1. Any party or Non-Party may challenge a designation of 18 confidentiality at any time that is consistent with the Court’s Scheduling 19 Order. 20 B. Meet and Confer 21 1. The Challenging Party shall initiate the dispute resolution process 22 under Local Rule 37.1 et seq. 23 C. The burden of persuasion in any such challenge proceeding shall be on 24 the Designating Party. Frivolous challenges, and those made for an improper 1 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 2 parties) may expose the Challenging Party to sanctions. Unless the Designating 3 Party has waived or withdrawn the confidentiality designation, all parties shall 4 continue to afford the material in question the level of protection to which it is 5 entitled under the Producing Party’s designation until the Court rules on the

6 challenge. 7 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL 8 A. Basic Principles 9 1. A Receiving Party may use Protected Material that is disclosed or 10 produced by another Party or by a Non-Party in connection with this 11 Action only for prosecuting, defending, or attempting to settle this Action. 12 Such Protected Material may be disclosed only to the categories of 13 persons and under the conditions described in this Order. When the 14 Action has been terminated, a Receiving Party must comply with the 15 provisions of Section XIV below. 16 2. Protected Material must be stored and maintained by a Receiving

17 Party at a location and in a secure manner that ensures that access is 18 limited to the persons authorized under this Order. 19 B. Disclosure of “CONFIDENTIAL” Information or Items 20 1. Unless otherwise ordered by the Court or permitted in writing by 21 the Designating Party, a Receiving Party may disclose any information or 22 item designated “CONFIDENTIAL” only to: 23 a. The Receiving Party’s Outside Counsel of Record in this 24 Action, as well as employees of said Outside Counsel of Record to 1 whom it is reasonably necessary to disclose the information for this 2 Action; 3 b. The officers, directors, and employees (including House 4 Counsel) of the Receiving Party to whom disclosure is reasonably 5 necessary for this Action;

6 c. Experts (as defined in this Order) of the Receiving Party to 7 whom disclosure is reasonably necessary for this Action and who 8 have signed the “Acknowledgment and Agreement to Be Bound” 9 (Exhibit A); 10 d. The Court and its personnel; 11 e. Court reporters and their staff; 12 f. Professional jury or trial consultants, mock jurors, and 13 Professional Vendors to whom disclosure is reasonably necessary 14 or this Action and who have signed the “Acknowledgment and 15 Agreement to be Bound” attached as Exhibit A hereto; 16 g. The author or recipient of a document containing the

17 information or a custodian or other person who otherwise 18 possessed or knew the information; 19 h. During their depositions, witnesses, and attorneys for 20 witnesses, in the Action to whom disclosure is reasonably 21 necessary provided: (i) the deposing party requests that the 22 witness sign the “Acknowledgment and Agreement to Be Bound;” 23 and (ii) they will not be permitted to keep any confidential 24 information unless they sign the “Acknowledgment and Agreement 1 to Be Bound,” unless otherwise agreed by the Designating Party or 2 ordered by the Court. Pages of transcribed deposition testimony or 3 exhibits to depositions that reveal Protected Material may be 4 separately bound by the court reporter and may not be disclosed to 5 anyone except as permitted under this Stipulated Protective Order;

6 and 7 i. Any mediator or settlement officer, and their supporting 8 personnel, mutually agreed upon by any of the parties engaged in 9 settlement discussions. 10 IX. PROTECTED MATERIAL SUPOENAED OR ORDERED PRODUCED 11 IN OTHER LITIGATION 12 A. If a Party is served with a subpoena or a court order issued in other 13 litigation that compels disclosure of any information or items designated in this 14 Action as “CONFIDENTIAL,” that Party must: 15 1. Promptly notify in writing the Designating Party. Such notification 16 shall include a copy of the subpoena or court order;

17 2. Promptly notify in writing the party who caused the subpoena or 18 order to issue in the other litigation that some or all of the material 19 covered by the subpoena or order is subject to this Protective Order. Such 20 notification shall include a copy of this Stipulated Protective Order; and 21 3. Cooperate with respect to all reasonable procedures sought to be 22 pursued by the Designating Party whose Protected Material may be 23 affected. 24 1 B. If the Designating Party timely seeks a protective order, the Party served 2 with the subpoena or court order shall not produce any information designated 3 in this action as “CONFIDENTIAL” before a determination by the Court from 4 which the subpoena or order issued, unless the Party has obtained the 5 Designating Party’s permission. The Designating Party shall bear the burden

6 and expense of seeking protection in that court of its confidential material and 7 nothing in these provisions should be construed as authorizing or encouraging a 8 Receiving Party in this Action to disobey a lawful directive from another court. 9 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 10 PRODUCED IN THIS LITIGATION 11 A. The terms of this Order are applicable to information produced by a Non- 12 Party in this Action and designated as “CONFIDENTIAL.” Such information 13 produced by Non-Parties in connection with this litigation is protected by the 14 remedies and relief provided by this Order. Nothing in these provisions should 15 be construed as prohibiting a Non-Party from seeking additional protections. 16 B. In the event that a Party is required, by a valid discovery request, to

17 produce a Non-Party’s confidential information in its possession, and the Party 18 is subject to an agreement with the Non-Party not to produce the Non-Party’s 19 confidential information, then the Party shall: 20 1. Promptly notify in writing the Requesting Party and the Non-Party 21 that some or all of the information requested is subject to a 22 confidentiality agreement with a Non-Party; 23 24 1 2. Promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this Action, the relevant discovery request(s), and a 3 reasonably specific description of the information requested; and 4 3. Make the information requested available for inspection by the 5 Non-Party, if requested.

6 C. If the Non-Party fails to seek a protective order from this court within 14 7 days of receiving the notice and accompanying information, the Receiving Party 8 may produce the Non-Party’s confidential information responsive to the 9 discovery request. If the Non-Party timely seeks a protective order, the 10 Receiving Party shall not produce any information in its possession or control 11 that is subject to the confidentiality agreement with the Non-Party before a 12 determination by the court. Absent a court order to the contrary, the Non-Party 13 shall bear the burden and expense of seeking protection in this court of its 14 Protected Material. 15 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 16 A. If a Receiving Party learns that, by inadvertence or otherwise, it has

17 disclosed Protected Material to any person or in any circumstance not 18 authorized under this Stipulated Protective Order, the Receiving Party must 19 immediately (1) notify in writing the Designating Party of the unauthorized 20 disclosures, (2) use its best efforts to retrieve all unauthorized copies of the 21 Protected Material, (3) inform the person or persons to whom unauthorized 22 disclosures were made of all the terms of this Order, and (4) request such person 23 or persons to execute the “Acknowledgment and Agreement to be Bound” that is 24 attached hereto as Exhibit A. 1 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 A. Non-Waiver of Privilege. As stated in the parties’ joint Rule 26(f) report 4 (ECF No. 22), the parties agree that they do not intend to disclose information 5 subject to a claim of attorney-client privilege, attorney work product protection, 6 protection from production or disclosure under the Health Insurance and 7 Portability Act (“HIPAA”) (including “Protected Health Information” as that term is defined in

) or the Federal Privacy Act of 1974, 5 8 U.S.C. § 552a, or any other privilege, immunity or protection from production or 9 disclosure (“Privileged Information”). Nevertheless, if a Producing Party 10 discloses Privileged Information, such disclosure (as distinct from use) shall be 11 deemed inadvertent without need of further showing under Federal Rule of 12 Evidence 502(b) and shall not constitute or be deemed a waiver or forfeiture of 13 the privilege or protection from discovery in this case or in any other federal or 14 state proceeding by that party (the “Disclosing Party”). This Section shall be interpreted to provide the maximum protection allowed by Federal Rule of 15 Evidence 502(d). 16 B. Notice of Production of Privileged Information. If a Party or non-Party 17 discovers that it has produced Privileged Information, it shall promptly notify 18 the Receiving Party of the production in writing and may demand that the 19 Receiving Party return or destroy the Privileged Information. In the event that a 20 Receiving Party receives information that it believes is subject to a good faith 21 claim of privilege by the Designating Party, the Receiving Party shall immediately refrain from examining the information and shall promptly notify 22 the Designating Party in writing that the Receiving Party possesses potentially 23 Privileged Information. The Designating Party shall have seven (7) days to 24 1 assert privilege over the identified information. If the Designating Party does 2 not assert a claim of privilege within the 7-day period, the information in 3 question shall be deemed non-privileged. 4 C. Recall of Privileged Information. If the Designating Party has notified 5 the Receiving Party that it is claiming privilege over previously produced documents, or has confirmed it is claiming privilege over a production called to 6 its attention by the Receiving Party, the Receiving Party shall within seven (7) 7 days of receiving such notification or confirmation: (1) destroy, delete, or return 8 to the Designating Party all copies or versions of the produced Privileged 9 Information requested to be returned or destroyed; (2) delete from its work 10 product or other materials any quoted or paraphrased portions of the produced 11 Privileged Information; (3) ensure that produced Privileged Information is not 12 disclosed in any manner to any Party or non-Party; and (4) confirm by way of letter to the Designating Party that all copies or versions of the produced 13 Privileged Information have been destroyed, deleted, or returned. Within 14 fourteen (14) days of the notification that such Privileged Information has been 15 destroyed, deleted, or returned (“Clawed-Back Information”), the Disclosing 16 Party shall produce a privilege log with respect to the Clawed-Back Information. 17 Within fourteen (14) days after receiving the Disclosing Party’s privilege log with 18 respect to such Clawed-Back Information, a receiving party may notify the 19 Disclosing Party in writing an objection to a claim of privilege or protection from disclosure with respect to the Clawed-Back Information by initiating the dispute 20 resolution process under Local Rule 37-1 et seq. 21 XIII. MISCELLANEOUS 22 A. Right to Further Relief 23 1. Nothing in this Order abridges the right of any person to seek its 24 modification by the Court in the future. 1 B. Right to Assert Other Objections 2 1. By stipulating to the entry of this Protective Order, no Party waives 3 any right it otherwise would have to object to disclosing or producing any 4 information or item on any ground not addressed in this Stipulated 5 Protective Order. Similarly, no Party waives any right to object on any

6 ground to use in evidence of any of the material covered by this Protective 7 Order. 8 C. Filing Protected Material 9 1. A Party that seeks to file under seal any Protected Material must 10 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 12 Protected Material at issue. If a Party's request to file Protected Material 13 under seal is denied by the Court, then the Receiving Party may file the 14 information in the public record unless otherwise instructed by the Court. 15 16

17 XIV. FINAL DISPOSITION 18 A. After the final disposition of this Action, as defined in Section V, within 19 sixty (60) days of a written request by the Designating Party, each Receiving 20 Party must return all Protected Material to the Producing Party or destroy such 21 material. As used in this subdivision, “all Protected Material” includes all copies, 22 abstracts, compilations, summaries, and any other format reproducing or 23 capturing any of the Protected Material. Whether the Protected Material is 24 returned or destroyed, the Receiving Party must submit a written certification to 1 the Producing Party (and, if not the same person or entity, to the Designating 2 Party) by the 60 day deadline that (1) identifies (by category, where appropriate) 3 all the Protected Material that was returned or destroyed and (2) affirms that the 4 Receiving Party has not retained any copies, abstracts, compilations, summaries 5 or any other format reproducing or capturing any of the Protected Material.

6 Notwithstanding this provision, Counsel are entitled to retain an archival copy of 7 all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 8 memoranda, correspondence, deposition and trial exhibits, expert reports, 9 attorney work product, and consultant and expert work product, even if such 10 materials contain Protected Material. Any such archival copies that contain or 11 constitute Protected Material remain subject to this Protective Order as set forth 12 in Section V. 13 B. Any violation of this Order may be punished by any and all appropriate 14 measures including, without limitation, contempt proceedings and/or monetary 15 sanctions. 16

17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

18 Dated: September 13, 2021 19 /s/ Omar G. Qureshi 20 Omar G. Qureshi (Cal. Bar No. 323493) Brian M. Adesman (Cal. Bar No. 312663) 21 QURESHI LAW 1625 W. Olympic Boulevard, Suite 500 22 Los Angeles, California 90015 Telephone: (213) 315-5442 23 Facsimile: (213) 277-8989 E-mail: [email protected] 24 1 Attorney for Plaintiff William Allen 2 3 /s/ Matthew J. Smock Matthew J. Smock (Cal. Bar No. 293542) 4 US ATTORNEY’S OFFICE Federal Building, Suite 7516 5 300 North Los Angeles Street Los Angeles, California 90012 6 Telephone: (213) 894-0397 Facsimile: (213) 894-7819 7 E-mail: [email protected] 8 Attorney for Defendant Frank Kendall III 9 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 10 11 Dated: September 16, 2021 /s/ Autumn D. Spaeth HONORABLE AUTUMN D. SPAETH 12 United States Magistrate Judge 13 14 15 16 17 18 19 20 21 22 23 24 1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

3 I, [print or type full name], of 4 [print or type full address], declare under penalty of perjury that I 5 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 7 the case of William Allen v. Frank Kendall III, Case No. 8:20-cv-01756-JLS-ADS. I 8 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 to 10 sanctions and punishment in the nature of contempt. I solemnly promise that I will not 11 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 provisions 13 of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint [print or 18 type full name] of [print or type full address and 19 telephone number] as my California agent for service of process in connection with this 20 action or any proceedings related to enforcement of this Stipulated Protective Order. 21 Date: 22 City and State where sworn and signed: 23 Printed Name: 24 Signature: