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8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA

10 WESTERN DIVISION 11 CHARF LLOYD, an individual, by and CASE NO. 2:21-cv-06229-FMO-JDE through his Guardian ad Litem and 12 Conservator, The Los Angeles County Public Guardian, [Assigned to Judge Fernando M. 13 Olguin, Courtroom "6D"] Plaintiff, 14 v. STIPULATED PROTECTIVE 15 ORDER CITY OF LOS ANGELES, and DOES 16 1-10, inclusive,

17 Defendants.

18 Pursuant to the parties’ Stipulation and for good cause shown, the Court finds 19 and orders as follows. 20 1. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 23 proprietary or private information for which special protection from public 24 disclosure and from use for any purpose other than pursuing this litigation may be 25 warranted, including, but not limited to, the personnel records of sworn peace 26 officers, City of Los Angeles Police Department internal investigative records, and 27 medical and other records relating to Plaintiff's personal and confidential information. Accordingly, the parties hereby stipulate to and petition the Court to 1 enter the following Stipulated Protective Order. The parties acknowledge that this 2 Order does not confer blanket protections on all disclosures or responses to 3 discovery and that the protection it affords from public disclosure and use extends 4 only to the limited information or items that are entitled to confidential treatment 5 under the applicable legal principles. 6 2. GOOD CAUSE STATEMENT 7 This action is likely to involve confidential information pertaining to peace 8 officer personnel records, investigative records and other materials subject to 9 privacy protections for which special protection from public disclosure and from use 10 for any purpose other than prosecution of this action is warranted. Limiting 11 disclosure of these documents to the context of this litigation as provided herein 12 will, accordingly, further important law enforcement objections and interests, 13 including the safety of personnel and the public, as well as individual privacy rights 14 of Plaintiff, the Defendant(s), and third parties. Such confidential materials and 15 information consist of, among other things, materials entitled to privileges and/or 16 protections under the following: United States Constitution, First Amendment; the 17 California Constitution, Article I, Section 1; California Penal Code §§ 832.5, 832.7 18 and 832.8; California Evidence Code §§ 1040 and 1043 et. seq; the Privacy Act of 19 1974,

; Health Insurance Portability and Accountability Act of 1996 20 (HIPPA); the right to privacy; decisional law relating to such provisions; and 21 information otherwise generally unavailable to the public, or which may be 22 privileged or otherwise protected from disclosure under state or federal statutes, 23 court rules, case decisions, or common law. Defendant City also contends that such 24 confidential materials and information consist of materials may be entitled to the 25 Official Information Privilege and/or deliberative process privileges. 26 Confidential information with respect to the Defendant may include but is not 27 limited to: personnel files; internal investigative files and documents; email and 1 public in the ordinary course of business, as well as other information that is not 2 generally available to the public and is subject to the Official Information Privilege 3 and other privileges. Confidential information with financial records; email and 4 written correspondence records; video footage and/or photographs of the incident; 5 and psychological and medical notes, evaluations, reports, and treatment plans. 6 Testimony taken at a deposition may be designated as Confidential by making 7 a statement to that effect on the record at the deposition. Arrangements shall be 8 made with the court reporter transcribing the deposition to separately bind such 9 portions of the transcript containing information designated as Confidential, and to 10 label such portions appropriately. Confidential photographs, video or audio footage 11 obtained through the course of discovery or otherwise may not be used for any 12 purpose other than litigating this lawsuit. The parties agree to refrain from directly 13 or indirectly disclosing or publicly disseminating confidential deposition testimony, 14 and/or photographs, video or audio footage obtained through the course of discovery 15 or otherwise, specifically including, but not limited to, dissemination via billboard 16 advertisements, print and online media organizations, or any other internet posting 17 or social media. If any party intends to use such confidential materials for any 18 purpose other than litigating this lawsuit, the party seeking public disclosure must 19 first seek approval from the Court. 20 In light of the nature of the claims and allegations in this case and the parties’ 21 representations that discovery in this case will involve the production of confidential 22 records, and in order to expedite the flow of information, to facilitate the prompt 23 resolution of disputes over confidentiality of discovery materials, to adequately 24 protect information the parties are entitled to keep confidential, to ensure that the 25 parties are permitted reasonable necessary uses of such material in connection with 26 this action, to address their handling of such material at the end of the litigation, and 27 to serve the ends of justice, a protective order for such information is justified in this 1 without a good faith belief that such information/documents have been maintained 2 in a confidential, non-public manner, and that there is good cause or a compelling 3 reason why it should not be part of the public record of this case. 4 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 5 The parties further acknowledge, as set forth in Section 14.3, below, that this 6 Stipulated Protective Order does not entitle them to file confidential information 7 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 8 and the standards that will be applied when a party seeks permission from the court 9 to file material under seal. There is a strong presumption that the public has a right 10 of access to judicial proceedings and records in civil cases. In connection with non- 11 dispositive motions, good cause must be shown to support a filing under seal. See 12 Kamakana v. City and County of Honolulu,

(9th Cir. 2006), 13 Phillips v. Gen. Motors Corp.,

, 1210-11 (9th Cir. 2002), Makar- 14 Welbon v. Sony Electrics, Inc.,

(E.D. Wis. 1999) (even 15 stipulated protective orders require good cause showing), and a specific showing of 16 good cause or compelling reasons with proper evidentiary support and legal 17 justification, must be made with respect to Protected Material that a party seeks to 18 file under seal. The parties’ mere designation of Disclosure or Discovery Material as 19 CONFIDENTIAL does not, without the submission of competent evidence by 20 declaration, establishing that the material sought to be filed under seal qualifies as 21 confidential, privileged, or otherwise protectable, constitute good cause. 22 Further, if a party requests sealing related to a dispositive motion or trial, then 23 compelling reasons, not only good cause, for the sealing must be shown, and the 24 relief sought shall be narrowly tailored to serve the specific interest to be protected. 25 See Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For 26 each item or type of information, document, or thing sought to be filed or introduced 27 under seal, the party seeking protection must articulate compelling reasons, 1 Again, competent evidence supporting the application to file documents under seal 2 must be provided by declaration. 3 Any document that is not confidential, privileged, or otherwise protectable in 4 its entirety will not be filed under seal if the confidential portions can be redacted. If 5 documents can be redacted, then a redacted version for public viewing, omitting 6 only the confidential, privileged, or otherwise protectable portions of the document, 7 shall be filed. Any application that seeks to file documents under seal in their 8 entirety should include an explanation of why redaction is not feasible. 9 4. DEFINITIONS 10 4.1 Action: Charf Lloyd v. City of Los Angeles, et al., 2:21-cv-06229- 11 FMO-JDE 12 4.2 Challenging Party: a Party or Non-Party that challenges the 13 designation of information or items under this Order. 14 4.3 “CONFIDENTIAL” Information or Items: information (regardless of 15 how it is generated, stored or maintained) or tangible things that qualify for 16 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 17 the Good Cause Statement. 18 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 19 their support staff). 20 4.5 Designating Party: a Party or Non-Party that designates information or 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL.” 23 4.6 Disclosure or Discovery Material: all items or information, regardless 24 of the medium or manner in which it is generated, stored, or maintained (including, 25 among other things, testimony, transcripts, and tangible things), that are produced or 26 generated in disclosures or responses to discovery. 27 / / / 1 4.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as 3 an expert witness or as a consultant in this Action. 4 4.8 House Counsel: attorneys who are employees of a party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 7 4.9 Non-Party: any natural person, partnership, corporation, association or 8 other legal entity not named as a Party to this action. 9 4.10 Outside Counsel of Record: attorneys who are not employees of a party 10 to this Action but are retained to represent a party to this Action and have appeared 11 in this Action on behalf of that party or are affiliated with a law firm that has 12 appeared on behalf of that party, and includes support staff. 13 4.11 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 4.13 Professional Vendors: persons or entities that provide litigation support 19 services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) 21 and their employees and subcontractors. 22 4.14 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 4.15 Receiving Party: a Party that receives Disclosure or Discovery 25 Material from a Producing Party. 26 / / / 27 / / / 1 5. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the 8 trial judge and other applicable authorities. This Order does not govern the use of 9 Protected Material at trial. 10 6. DURATION 11 Once a case proceeds to trial, information that was designated as 12 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 13 as an exhibit at trial becomes public and will be presumptively available to all 14 members of the public, including the press, unless compelling reasons supported by 15 specific factual findings to proceed otherwise are made to the trial judge in advance 16 of the trial. See Kamakana,

(distinguishing “good cause” 17 showing for sealing documents produced in discovery from “compelling reasons” 18 standard when merits-related documents are part of court record). Accordingly, the 19 terms of this protective order do not extend beyond the commencement of the trial. 20 7. DESIGNATING PROTECTED MATERIAL 21 7.1 Exercise of Restraint and Care in Designating Material for 22 Protection. Each Party or Non-Party that designates information or items for 23 protection under this Order must take care to limit any such designation to specific 24 material that qualifies under the appropriate standards. The Designating Party must 25 designate for protection only those parts of material, documents, items or oral or 26 written communications that qualify so that other portions of the material, 27 documents, items or communications for which protection is not warranted are not 1 swept unjustifiably within the ambit of this Order. 2 Mass, indiscriminate or routinized designations are prohibited. Designations 3 that are shown to be clearly unjustified or that have been made for an improper 4 purpose (e.g., to unnecessarily encumber the case development process or to impose 5 unnecessary expenses and burdens on other parties) may expose the Designating 6 Party to sanctions. 7 If it comes to a Designating Party’s attention that information or items that it 8 designated for protection do not qualify for protection, that Designating Party must 9 promptly notify all other Parties that it is withdrawing the inapplicable designation. 10 7.2 Manner and Timing of Designations. Except as otherwise provided in 11 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material 12 that qualifies for protection under this Order must be clearly so designated before 13 the material is disclosed or produced. 14 Designation in conformity with this Order requires: 15 (a) For information in documentary form (e.g., paper or electronic 16 documents, but excluding transcripts of depositions or other pretrial or trial 17 proceedings), that the Producing Party affix at a minimum, the legend 18 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 19 contains protected material. If only a portion of the material on a page qualifies for 20 protection, the Producing Party also must clearly identify the protected portion(s) 21 (e.g., by making appropriate markings in the margins). 22 A Party or Non-Party that makes original documents available for inspection 23 need not designate them for protection until after the inspecting Party has indicated 24 which documents it would like copied and produced. During the inspection and 25 before the designation, all of the material made available for inspection shall be 26 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 27 documents it wants copied and produced, the Producing Party must determine which 1 documents, or portions thereof, qualify for protection under this Order. Then, before 2 producing the specified documents, the Producing Party must affix the 3 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 4 portion of the material on a page qualifies for protection, the Producing Party also 5 must clearly identify the protected portion(s) (e.g., by making appropriate markings 6 in the margins) 7 (b) For testimony given in depositions that the Designating Party identifies 8 the Disclosure or Discovery Material on the record, before the close of the 9 deposition all protected testimony. 10 (c) For information produced in some form other than documentary and 11 for any other tangible items, that the Producing Party affix in a prominent place on 12 the exterior of the container or containers in which the information is stored the 13 legend “CONFIDENTIAL.” If only a portion or portions of the information 14 warrants protection, the Producing Party, to the extent practicable, shall identify the 15 protected portion(s). 16 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 17 failure to designate qualified information or items does not, standing alone, waive 18 the Designating Party’s right to secure protection under this Order for such material. 19 Upon timely correction of a designation, the Receiving Party must make reasonable 20 efforts to assure that the material is treated in accordance with the provisions of this 21 Order. 22 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 23 8.1. 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 25 Scheduling Order. 26 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 27 resolution process under Local Rule 37-1 et seq. 1 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 2 joint stipulation pursuant to Local Rule 37-2. 3 8.4 Burden. The burden of persuasion in any such challenge proceeding 4 shall be on the Designating Party. Frivolous challenges, and those made for an 5 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 6 other parties) may expose the Challenging Party to sanctions. Unless the 7 Designating Party has waived or withdrawn the confidentiality designation, all 8 parties shall continue to afford the material in question the level of protection to 9 which it is entitled under the Producing Party’s designation until the Court rules on 10 the challenge. 11 9. ACCESS TO AND USE OF PROTECTED MATERIAL 12 9.1 Basic Principles. A Receiving Party may use Protected Material that is 13 disclosed or produced by another Party or by a Non-Party in connection with this 14 Action only for prosecuting, defending or attempting to settle this Action. Such 15 Protected Material may be disclosed only to the categories of persons and under the 16 conditions described in this Order. When the Action has been terminated, a 17 Receiving Party must comply with the provisions of section 15 below (FINAL 18 DISPOSITION). 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Order. 22 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 23 otherwise ordered by the court or permitted in writing by the Designating Party, a 24 Receiving Party may disclose any information or item designated 25 “CONFIDENTIAL” only to: 26 (a) the Receiving Party’s Outside Counsel of Record in this Action, 27 as well as employees of said Outside Counsel of Record to whom it is reasonably 1 necessary to disclose the information for this Action; 2 (b) the officers, directors, and employees (including House Counsel) 3 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 4 (c) Experts (as defined in this Order) of the Receiving Party to 5 whom disclosure is reasonably necessary for this Action and who have signed the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (d) the court and its personnel; 8 (e) court reporters and their staff; 9 (f) professional jury or trial consultants, mock jurors, and 10 Professional Vendors to whom disclosure is reasonably necessary for this Action 11 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 12 A); 13 (g) the author or recipient of a document containing the information 14 or a custodian or other person who otherwise possessed or knew the information; 15 (h) during their depositions, witnesses, and attorneys for witnesses, 16 in the Action to whom disclosure is reasonably necessary provided: (1) the deposing 17 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 18 they will not be permitted to keep any confidential information unless they sign the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 20 agreed by the Designating Party or ordered by the court. Pages of transcribed 21 deposition testimony or exhibits to depositions that reveal Protected Material may 22 be separately bound by the court reporter and may not be disclosed to anyone except 23 as permitted under this Stipulated Protective Order; and 24 (i) any mediators or settlement officers and their supporting 25 personnel, mutually agreed upon by any of the parties engaged in settlement 26 discussions. 27 / / / 1 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 2

3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification 7 shall include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or 9 order to issue in the other litigation that some or all of the material covered by the 10 subpoena or order is subject to this Protective Order. Such notification shall include 11 a copy of this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be 13 pursued by the Designating Party whose Protected Material may be affected. If the 14 Designating Party timely seeks a protective order, the Party served with the 15 subpoena or court order shall not produce any information designated in this action 16 as “CONFIDENTIAL” before a determination by the court from which the 17 subpoena or order issued, unless the Party has obtained the Designating Party’s 18 permission. The Designating Party shall bear the burden and expense of seeking 19 protection in that court of its confidential material and nothing in these provisions 20 should be construed as authorizing or encouraging a Receiving Party in this Action 21 to disobey a lawful directive from another court. 22 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 23 PRODUCED IN THIS LITIGATION 24 25 (a) The terms of this Order are applicable to information produced by a 26 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 27 produced by Non-Parties in connection with this litigation is protected by the 1 construed as prohibiting a Non-Party from seeking additional protections. 2 (b) In the event that a Party is required, by a valid discovery request, 3 to produce a Non-Party’s confidential information in its possession, and the Party is 4 subject to an agreement with the Non-Party not to produce the Non-Party’s 5 confidential information, then the Party shall: 6 (1) promptly notify in writing the Requesting Party and the Non-Party 7 that some or all of the information requested is subject to a confidentiality 8 agreement with a Non-Party; 9 (2) promptly provide the Non-Party with a copy of the Stipulated 10 Protective Order in this Action, the relevant discovery request(s), and a reasonably 11 specific description of the information requested; and 12 (3) make the information requested available for inspection by the Non- 13 Party, if requested. 14 (c) If the Non-Party fails to seek a protective order from this court within 15 14 days of receiving the notice and accompanying information, the Receiving Party 16 may produce the Non-Party’s confidential information responsive to the discovery 17 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 18 not produce any information in its possession or control that is subject to the 19 confidentiality agreement with the Non-Party before a determination by the court. 20 Absent a court order to the contrary, the Non-Party shall bear the burden and 21 expense of seeking protection in this court of its Protected Material. 22 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 24 Protected Material to any person or in any circumstance not authorized under this 25 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 26 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 27 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 1 persons to whom unauthorized disclosures were made of all the terms of this Order, 2 and (d) request such person or persons to execute the “Acknowledgment an 3 Agreement to Be Bound” attached hereto as Exhibit A. 4 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 5 OTHERWISE PROTECTED MATERIAL 6 When a Producing Party gives notice to Receiving Parties that certain 7 inadvertently produced material is subject to a claim of privilege or other protection, 8 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 9 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 10 may be established in an e-discovery order that provides for production without 11 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 12 as the parties reach an agreement on the effect of disclosure of a communication or 13 information covered by the attorney-client privilege or work product protection, the 14 parties may incorporate their agreement in the stipulated protective order submitted 15 to the court. 16 14. MISCELLANEOUS 17 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 18 person to seek its modification by the Court in the future. 19 14.2 Right to Assert Other Objections. By stipulating to the entry of this 20 Protective Order, no Party waives any right it otherwise would have to object to 21 disclosing or producing any information or item on any ground not addressed in this 22 Stipulated Protective Order. Similarly, no Party waives any right to object on any 23 ground to use in evidence of any of the material covered by this Protective Order. 24 14.3 Filing Protected Material. A Party that seeks to file under seal any 25 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 26 only be filed under seal pursuant to a court order authorizing the sealing of the 27 specific Protected Material. If a Party’s request to file Protected Material under seal 1 is denied by the court, then the Receiving Party may file the information in the 2 public record unless otherwise instructed by the Court. 3 15. FINAL DISPOSITION 4 After the final disposition of this Action, as defined in paragraph 6, within 60 5 days of a written request by the Designating Party, each Receiving Party must return 6 all Protected Material to the Producing Party or destroy such material. As used in 7 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 8 summaries, and any other format reproducing or capturing any of the Protected 9 Material. Whether the Protected Material is returned or destroyed, the Receiving 10 Party must submit a written certification to the Producing Party (and, if not the same 11 person or entity, to the Designating Party) by the 60-day deadline that (1) identifies 12 (by category, where appropriate) all the Protected Material that was returned or 13 destroyed and (2) affirms that the Receiving Party has not retained any copies, 14 abstracts, compilations, summaries or any other format reproducing or capturing any 15 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 16 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 17 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 18 reports, attorney work product, and consultant and expert work product, even if such 19 materials contain Protected Material. Any such archival copies that contain or 20 constitute Protected Material remain subject to this Protective Order as set forth in 21 Section 6 (DURATION). 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 1 16. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 || including, without limitation, contempt proceedings and/or monetary sanctions.

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: December 15, 2021 7 D. EARLY 8 ited States Magistrate Judge 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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], declare under penalty of perjury 6 that I have read in its entirety and understand the Protective Order that was issued 7 by the United States District Court for the Central District of California on 8 _________________________ in the case of Charf Lloyd v. City of Los Angeles, et 9 al., Case No. 2:21-cv-06229-FMO-JDE. I agree to comply with and to be bound by 10 all the terms of this Protective Order and I understand and acknowledge that failure 11 to so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any information 13 or item that is subject to this Protective Order to any person or entity except in strict 14 compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Protective Order, even if such enforcement proceedings occur after termination of 18 this action. I hereby appoint __________________________ [print or type full 19 name] of _______________________________________ [print or type full address 20 and telephone number] as my California agent for service of process in connection 21 with this action or any proceedings related to enforcement of this Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24

25 Printed name: _______________________________ 26

27 Signature: ________________________________