1 STEPHANIE FORMAN, ESQ.; STATE BAR NO.: 195757 DIANA M. RIVERA, ESQ.; STATE BAR NO.: 222025 2 THARPE & HOWELL, LLP 3 15250 Ventura Blvd., Ninth Floor Sherman Oaks, California 91403 4 (818) 205-9955; (818) 205-9944 fax E-Mail: [email protected] 5 E-Mail: [email protected]

6 Attorneys for Defendant, LOWE’S HOME CENTERS, LLC 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 DANIEL KOSTRIKIN, No. 2:23-cv-2535 DAD DB 11 Plaintiff, STIPULATED PROTECTIVE ORDER 12 v. 13 LOWE’S HOME CENTERS, LLC 14 DOES 1 To 25

15 Defendants.

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19 1. A. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, proprietary, 21 or private information for which special protection from public disclosure and from 22 use for any purpose other than prosecuting this litigation may be warranted. 23 Accordingly, the parties hereby stipulate to and petition the Court to enter the 24 following Stipulated Protective Order. The parties acknowledge that this Order does 25 not confer blanket protections on all disclosures or responses to discovery and that the 26 protection it affords from public disclosure and use extends only to the limited 27 information or items that are entitled to confidential treatment under the applicable 28 1 that this Stipulated Protective Order does not entitle them to file confidential 2 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 3 followed and the standards that will be applied when a party seeks permission from 4 the court to file material under seal. 5 B. GOOD CAUSE STATEMENT 6 Federal Rules of Civil Procedure, Rule 26(c)(1) states in pertinent part, that the 7 Court, upon a showing of good cause may “issue an order to protect a party from 8 annoyance, embarrassment, oppression, or undue burden or expense.” Fed.R.Civ.P. 9 26(c)(1). In the instant matter, Defendant Lowe’s Home Centers, LLC’s Confidential 10 Documents contain proprietary and confidential trade secret information relating to 11 Defendant Lowe’s Home Centers, LLC’s business practices, policies and procedures, 12 its safety protocol, and information about its video surveillance system. Defendant 13 Lowe’s Home Centers, LLC. (“Defendant” or “Lowe’s”) derives independent 14 economic value from maintaining the confidentiality of the policies and procedures set 15 forth in these Confidential Documents. 16 Defendant is a retailer in the home improvement industry and has conducted 17 business in California since 1998. The home improvement retail industry is very 18 competitive. As a result of years of investing time and money in research and 19 investigation, Defendant developed the policies contained in the Confidential 20 Documents for the purposes of maintaining the security of its facilities, providing 21 quality customer service, and ensuring the safety of its employees, customers, and 22 other invitees. These policies and procedures, as memorialized in the Confidential 23 Documents, were created and generated by Lowe’s for Lowe’s, and are used for the 24 purposes of maintaining safety at its stores and creating efficient and organized work 25 environments for its employees. As a result, Defendant is able to minimize the waste 26 of any resources, which is a key factor in generating profitability for its business. 27 Defendant derives economic value from maintaining the secrecy of its Confidential 28 Documents. If disclosed to the public, the trade secret information contained in 1 Defendant’s Confidential Documents would reveal Defendant’s internal operations 2 and could potentially be used by competitors as a means to compete for its customers, 3 interfere with its business plans and thereby gain unfair business advantages. If 4 Defendant’s safety protocol were revealed to the general public, it would hinder 5 Defendant’s ability to effectively resolve and minimize liability claims, and its goal of 6 protecting its customers and employees from theft and other crimes. Unrestricted or 7 unprotected disclosure of such information would result in prejudice or harm to 8 Defendant by revealing Lowe’s competitive confidential information, which has been 9 developed at the expense of Lowe’s and which represents valuable tangible and 10 intangible assets. Accordingly, the parties respectfully submit that there is good cause 11 for the entry of this Protective Order. 12 2. DEFINITIONS 13 2.1 Action: Daniel Kostrikin v Lowe’s Home Centers, LLC., Case No.: 2:23- 14 cv-02535-DAD-DB. 15 2.2 Challenging Party: a Party or Non-Party that challenges the designation 16 of information or items under this Order. 17 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 18 how it is generated, stored or maintained) or tangible things that qualify for protection 19 under 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 25 “CONFIDENTIAL.” 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, 28 among other things, testimony, transcripts, and tangible things), that are produced or 1 generated in disclosures or responses to discovery in this matter. 2 2.7 Expert: a person with specialized knowledge or experience in a matter 3 pertinent to the litigation who has been retained by a Party or its counsel to serve as 4 an expert witness or as a consultant in this Action. 5 2.8 House Counsel: attorneys who are employees of a party to this Action. 6 House Counsel does not include Outside Counsel of Record or any other outside 7 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 11 party to this Action but are retained to represent or advise a party to this Action and 12 have appeared in this Action on behalf of that party or are affiliated with a law firm 13 which 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 24 designated as “CONFIDENTIAL.” 25 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 26 from a Producing Party. 27 3. SCOPE 28 The protections conferred by this Stipulation and Order cover not only Protected 1 Material (as defined above), but also (1) any information copied or extracted from 2 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 3 Material; and (3) any testimony, conversations, or presentations by Parties or their 4 Counsel that might reveal Protected Material. 5 Any use of Protected Material at trial shall be governed by the orders of the trial 6 judge. This Order does not govern the use of Protected Material at trial. 7 4. DURATION 8 Once a case proceeds to trial, all of the information that was designated as 9 confidential or maintained pursuant to this protective order becomes public and will 10 be presumptively available to all members of the public, including the press, unless 11 compelling reasons supported by specific factual findings to proceed otherwise are 12 made to the trial judge in advance of the trial. See Kamakana v. City and County of 13 Honolulu,

(9th Cir. 2006) (distinguishing “good cause” 14 showing for sealing documents produced in discovery from “compelling reasons” 15 standard when merits-related documents are part of court record). Accordingly, the 16 terms of this protective order do not extend beyond the commencement of the trial. 17 5. DESIGNATING PROTECTED MATERIAL 18 5.1 Exercise of Restraint and Care in Designating Material for Protection. 19 Each Party or Non-Party that designates information or items for protection under 20 this Order must take care to limit any such designation to specific material that 21 qualifies under the appropriate standards. The Designating Party must designate for 22 protection only those parts of material, documents, items, or oral or written 23 communications that qualify so that other portions of the material, documents, items, 24 or communications for which protection is not warranted are not swept unjustifiably 25 within the ambit of this Order. 26 Mass, indiscriminate, or routinized designations are prohibited. Designations 27 that are shown to be clearly unjustified or that have been made for an improper purpose 28 (e.g., to unnecessarily encumber the case development process or to impose 1 unnecessary expenses and burdens on other parties) may expose the Designating Party 2 to sanctions. 3 If it comes to a Designating Party’s attention that information or items that it 4 designated for protection do not qualify for protection, that Designating Party must 5 promptly notify all other Parties that it is withdrawing the inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided in 7 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 8 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 9 under this Order must be clearly so designated before the material is disclosed or 10 produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions or other pretrial or trial 14 proceedings), that the Producing Party affix at a minimum, the legend 15 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 16 contains protected material. If only a portion or portions of the material on a page 17 qualifies for protection, the Producing Party also must clearly identify the protected 18 portion(s) (e.g., by making appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and before 22 the designation, all of the material made available for inspection shall be deemed 23 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 24 copied and produced, the Producing Party must determine which documents, or 25 portions thereof, qualify for protection under this Order. Then, before producing the 26 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 27 to each page that contains Protected Material. If only a portion or portions of the 28 material on a page qualifies for protection, the Producing Party also must clearly 1 identify the protected portion(s) (e.g., by making appropriate markings in the margins). 2 (b) for testimony given in depositions that the Designating Party identify 3 the Disclosure or Discovery Material on the record, before the close of the deposition 4 all protected testimony. 5 (c) for information produced in some form other than documentary and for 6 any other tangible items, that the Producing Party affix in a prominent place on the 7 exterior of the container or containers in which the information is stored the legend 8 “CONFIDENTIAL.” If only a portion or portions of the information warrants 9 protection, the Producing Party, to the extent practicable, shall identify the protected 10 portion(s). 11 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 12 failure to designate qualified information or items does not, standing alone, waive the 13 Designating Party’s right to secure protection under this Order for such material. Upon 14 timely correction of a designation, the Receiving Party must make reasonable efforts 15 to assure that the material is treated in accordance with the provisions of this Order. 16 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 18 designation of confidentiality at any time that is consistent with the Court’s Scheduling 19 Order. 20 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 21 resolution process under Local Rule 37-1 et seq. 22 6.3 The burden of persuasion in any such challenge proceeding shall be on 23 the Designating Party. Frivolous challenges, and those made for an improper purpose 24 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 25 expose the Challenging Party to sanctions. Unless the Designating Party has waived 26 or withdrawn the confidentiality designation, all parties shall continue to afford the 27 material in question the level of protection to which it is entitled under the Producing 28 Party’s designation until the Court rules on the challenge. 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this 4 Action only for prosecuting, defending, or attempting to settle this Action. Such 5 Protected Material may be disclosed only to the categories of persons and under the 6 conditions described in this Order. When the Action has been terminated, a Receiving 7 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 8 Protected Material must be stored and maintained by a Receiving Party at a 9 location and in a secure manner that ensures that access is limited to the persons 10 authorized under this Order. 11 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 12 otherwise ordered by the court or permitted in writing by the Designating Party, a 13 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 14 only to: 15 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 16 well as employees of said Outside Counsel of Record to whom it is reasonably 17 necessary to disclose the information for this Action; 18 (b) the officers, directors, and employees (including House Counsel) of 19 the Receiving Party to whom disclosure is reasonably necessary for this Action; 20 (c) Experts (as defined in this Order) of the Receiving Party to whom 21 disclosure is reasonably necessary for this Action and who have signed the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (d) the court and its personnel; 24 (e) court reporters and their staff; 25 (f) professional jury or trial consultants, mock jurors, and Professional 26 Vendors to whom disclosure is reasonably necessary for this Action and who have 27 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 28 (g) the author or recipient of a document containing the information or a 1 custodian or other person who otherwise possessed or knew the information; 2 (h) during their depositions, witnesses, and attorneys for witnesses, in 3 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 4 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they 5 will not be permitted to keep any confidential information unless they sign the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 7 by the Designating Party or ordered by the court. Pages of transcribed deposition 8 testimony or exhibits to depositions that reveal Protected Material may be separately 9 bound by the court reporter and may not be disclosed to anyone except as permitted 10 under this Stipulated Protective Order; and 11 (i) any mediator or settlement officer, and their supporting personnel, 12 mutually agreed upon by any of the parties engaged in settlement discussions. 13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 14 IN OTHER LITIGATION 15 If a Party is served with a subpoena or a court order issued in other litigation 16 that compels disclosure of any information or items designated in this Action as 17 “CONFIDENTIAL,” that Party must: 18 (a) promptly notify in writing the Designating Party. Such notification 19 shall include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena or order 21 to issue in the other litigation that some or all of the material covered by the subpoena 22 or order is subject to this Protective Order. Such notification shall include a copy of 23 this Stipulated Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought to be pursued by 25 the Designating Party whose Protected Material may be affected. 26 If the Designating Party timely seeks a protective order, the Party served with 27 the subpoena or court order shall not produce any information designated in this action 28 as “CONFIDENTIAL” before a determination by the court from which the subpoena 1 or order issued, unless the Party has obtained the Designating Party’s permission. The 2 Designating Party shall bear the burden and expense of seeking protection in that court 3 of its confidential material and nothing in these provisions should be construed as 4 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 5 directive from another court. 6 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 7 PRODUCED IN THIS LITIGATION 8 (a) The terms of this Order are applicable to information produced by a Non- 9 Party in this Action and designated as “CONFIDENTIAL.” Such information 10 produced by Non-Parties in connection with this litigation is protected by the remedies 11 and relief provided by this Order. Nothing in these provisions should be construed as 12 prohibiting a Non-Party from seeking additional protections. 13 (b) In the event that a Party is required, by a valid discovery request, to produce 14 a Non-Party’s confidential information in its possession, and the Party is subject to an 15 agreement with the Non-Party not to produce the Non-Party’s confidential 16 information, then the Party shall: 17 (1) promptly notify in writing the Requesting Party and the Non-Party 18 that some or all of the information requested is subject to a confidentiality agreement 19 with a Non-Party; 20 (2) promptly provide the Non-Party with a copy of the Stipulated 21 Protective Order in this Action, the relevant discovery request(s), and a reasonably 22 specific description of the information requested; and 23 (3) make the information requested available for inspection by the 24 Non-Party, if requested. 25 (c) If the Non-Party fails to seek a protective order from this court within 14 26 days of receiving the notice and accompanying information, the Receiving Party may 27 produce the Non-Party’s confidential information responsive to the discovery request. 28 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 1 any information in its possession or control that is subject to the confidentiality 2 agreement with the Non-Party before a determination by the court. Absent a court 3 order to the contrary, the Non-Party shall bear the burden and expense of seeking 4 protection in this court of its Protected Material. 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 9 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 10 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 11 persons to whom unauthorized disclosures were made of all the terms of this Order, 12 and (d) request such person or persons to execute the “Acknowledgment and 13 Agreement to Be Bound” that is attached hereto as Exhibit A. 14 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 15 PROTECTED MATERIAL 16 When a Producing Party gives notice to Receiving Parties that certain 17 inadvertently produced material is subject to a claim of privilege or other protection, 18 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 19 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 20 may be established in an e-discovery order that provides for production without prior 21 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 22 parties reach an agreement on the effect of disclosure of a communication or 23 information covered by the attorney-client privilege or work product protection, the 24 parties may incorporate their agreement in the stipulated protective order submitted to 25 the court. 26 12. MISCELLANEOUS 27 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 28 person to seek its modification by the Court in the future. 1 12.2 Right to Assert Other Objections. By stipulating to the entry of this 2 Protective Order no Party waives any right it otherwise would have to object to 3 disclosing or producing any information or item on any ground not addressed in this 4 Stipulated Protective Order. Similarly, no Party waives any right to object on any 5 ground to use in evidence of any of the material covered by this Protective Order. 6 12.3 Filing Protected Material. A Party that seeks to file under seal any 7 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 8 only be filed under seal pursuant to a court order authorizing the sealing of the specific 9 Protected Material at issue. If a Party's request to file Protected Material under seal is 10 denied by the court, then the Receiving Party may file the information in the public 11 record unless otherwise instructed by the court. 12 13. FINAL DISPOSITION 13 After the final disposition of this Action, as defined in paragraph 4, within 60 14 days of a written request by the Designating Party, each Receiving Party must return 15 all Protected Material to the Producing Party or destroy such material. As used in this 16 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 17 summaries, and any other format reproducing or capturing any of the Protected 18 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 19 must submit a written certification to the Producing Party (and, if not the same person 20 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 21 category, where appropriate) all the Protected Material that was returned or destroyed 22 and (2)affirms that the Receiving Party has not retained any copies, abstracts, 23 compilations, summaries or any other format reproducing or capturing any of the 24 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 25 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 26 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 27 attorney work product, and consultant and expert work product, even if such materials 28 contain Protected Material. Any such archival copies that contain or constitute 1 Protected Material remain subject to this Protective Order as set forth in Section 4 2 (DURATION). 3 14. Any violation of this Order may be punished by any and all appropriate measures 4 including, without limitation, contempt proceedings and/or monetary sanctions. 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD: 7 8 THE VELEZ LAW FIRM, PC

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10 Dated: June 24, 2024 By: /s/Natalya V. Grunwald MARK P. VELEZ 11 NATALYA V. GRUNWALD 12 Attorneys for Plaintiff, DANIEL KOSTRIKIN 13

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15 THARPE & HOWELL, LLP 16

17 Dated: June 24, 2024 By: /s/Diana M. Rivera STEPHANIE FORMAN 18 DIANA M. RIVERA 19 Attorneys for Defendant, LOWE’S HOME CENTERS, LLC 20 Diana M. Rivera, the filer of this document, attests that all other signatories listed above, and on 21 whose behalf this filing is submitted, concur in the filing’s content and have authorized the filing, pursuant to L.R. 131(e). 22 23 ORDER 24 Pursuant to the parties’ stipulation, IT IS SO ORDERED. 25 IT IS FURTHER ORDERED THAT: 26 1. Requests to seal documents shall be made by motion before the same judge who will 27 decide the matter related to that request to seal. 28 1 2. The designation of documents (including transcripts of testimony) as confidential pursuant 2 to this order does not automatically entitle the parties to file such a document with the court under 3 seal. Parties are advised that any request to seal documents in this district is governed by Local Rule 4 141. In brief, Local Rule 141 provides that documents may only be sealed by a written order of the 5 court after a specific request to seal has been made. L.R. 141(a). However, a mere request to seal is 6 not enough under the local rules. In particular, Local Rule 141(b) requires that “[t]he ‘Request to 7 Seal Documents’ shall set forth the statutory or other authority for sealing, the requested duration, 8 the identity, by name or category, of persons to be permitted access to the document, and all relevant 9 information.” L.R. 141(b). 10 3. A request to seal material must normally meet the high threshold of showing that 11 “compelling reasons” support secrecy; however, where the material is, at most, “tangentially related” 12 to the merits of a case, the request to seal may be granted on a showing of “good cause.” Ctr. for 13 Auto Safety v. Chrysler Grp., LLC,

(9th Cir. 2016); Kamakana v. City 14 and County of Honolulu,

(9th Cir. 2006). 15 4. Nothing in this order shall limit the testimony of parties or non-parties, or the use of certain 16 documents, at any court hearing or trial – such determinations will only be made by the court at the 17 hearing or trial, or upon an appropriate motion. 18 5. With respect to motions regarding any disputes concerning this protective order which the 19 parties cannot informally resolve, the parties shall follow the procedures outlined in Local Rule 251. 20 Absent a showing of good cause, the court will not hear discovery disputes on an ex parte basis or 21 on shortened time. 22 6. The parties may not modify the terms of this Protective Order without the court’s approval. 23 If the parties agree to a potential modification, they shall submit a stipulation and proposed order for 24 the court’s consideration. 25 //// 26 //// 27 //// 28 //// 1 7. Pursuant to Local Rule 141.1(f), the court will not retain jurisdiction over enforcement of 2 the terms of this Protective Order after the action is terminated. 3 8. Any provision in the parties’ stipulation that is in conflict with anything in this order is 4 hereby DISAPPROVED. 5 DATED: June 27, 2024 /s/ DEBORAH BARNES 6 UNITED STATES MAGISTRATE JUDGE

7 8 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 I, ____________________________________________, [print or type full name] of 4 ______________________________________________, [print or type full address] 5 declare under penalty of perjury that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States District Court for 7 the Eastern District of California on ________________ [date] in the case of Daniel 8 Kostrikin v Lowe’s Home Centers, LLC., Case No.: 2:23-cv-02535-DAD-DB, I 9 agree to comply with and to be bound by all the terms of this Stipulated Protective 10 Order and I understand and acknowledge that failure to so comply could expose me 11 to sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for the 16 Eastern District of California for the purpose of enforcing the terms of this Stipulated 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 20 type full address and telephone number] as my California agent for service of 21 process in connection with this action or any proceedings related to enforcement of 22 this Stipulated Protective Order. 23 Date: _______________________________ 24 City and State where sworn and signed: ________________________________ 25 26 Printed Name: __________________________________________ 27 28 Signature: _____________________________________________