Justine Bontigao v. Nissan North America, Inc.

United States District Court for the Central District of California

Justine Bontigao v. Nissan North America, Inc.

Trial Court Opinion

1 AMIR NASSIHI (SBN 235936) [email protected] 2 SHOOK, HARDY & BACON L.L.P. 555 Mission Street, Suite 2300 3 San Francisco, CA 94105 Tel: (415) 544-1900 | Fax: (415) 391-0281 4 BRADY R. O’BRYAN (SBN 335729) 5 [email protected] KRISTINE AVENA (SBN 328593) 6 [email protected] NELSON X. LIU (SBN 339972) 7 [email protected] SHOOK, HARDY & BACON L.L.P. 8 Jamboree Center 5 Park Plaza, Suite 1600 9 Irvine, CA 92614-2546 Tel: (949) 475-1500 | Fax: (949) 475-0016 10 Attorneys for Defendant 11 NISSAN NORTH AMERICA, INC.

12 UNITED STATES DISTRICT COURT

13 CENTRAL DISTRICT OF CALIFORNIA

14 JUSTINE BONTIGAO, an individual, Case No. 2:25-CV-07557-SSC

15 Plaintiff, [PROPOSED] STIPULATED PROTECTIVE ORDER1 16 v.

17 NISSAN NORTH AMERICA, INC., a Delaware Corporation, and DOES 1 18 through 10, inclusive,

19 Defendants.

20 21 22 1. INTRODUCTION 23 1.1 Purposes and Limitations. Discovery in this action is likely to involve 24 production of confidential, proprietary, or private information for which special 25 protection from public disclosure and from use for any purpose other than prosecuting 26

27 1 This Stipulated Protective Order is substantially based on the model protective 1 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 2 petition the court to enter the following Stipulated Protective Order. The parties 3 acknowledge that this Order does not confer blanket protections on all disclosures or 4 responses to discovery and that the protection it affords from public disclosure and 5 use extends only to the limited information or items that are entitled to confidential 6 treatment under the applicable legal principles. 7 1.2 Good Cause Statement. This action is likely to involve trade secrets, 8 customer and pricing lists and other valuable research, development, commercial, 9 financial, technical and/or proprietary information for which special protection from 10 public disclosure and from use for any purpose other than prosecution of this action 11 is warranted. Such confidential and proprietary materials and information consist of, 12 among other things, confidential business or financial information, information 13 regarding confidential business practices, or other confidential research, 14 development, or commercial information (including information implicating privacy 15 rights of third parties), information otherwise generally unavailable to the public, or 16 which may be privileged or otherwise protected from disclosure under state or federal 17 statutes, court rules, case decisions, or common law. Accordingly, to expedite the 18 flow of information, to facilitate the prompt resolution of disputes over confidentiality 19 of discovery materials, to adequately protect information the parties are entitled to 20 keep confidential, to ensure that the parties are permitted reasonable necessary uses 21 of such material in preparation for and in the conduct of trial, to address their handling 22 at the end of the litigation, and serve the ends of justice, a protective order for such 23 information is justified in this matter. It is the intent of the parties that information 24 will not be designated as confidential for tactical reasons and that nothing be so 25 designated without a good faith belief that it has been maintained in a confidential, 26 non-public manner, and there is good cause why it should not be part of the public 27 record of this case. 1 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties 2 further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective 3 Order does not entitle them to file confidential information under seal; Local Rule 79- 4 5 sets forth the procedures that must be followed and the standards that will be applied 5 when a party seeks permission from the court to file material under seal. 6 There is a strong presumption that the public has a right of access to judicial 7 proceedings and records in civil cases. In connection with non-dispositive motions, 8 good cause must be shown to support a filing under seal. See Kamakana v. City and 9 Cnty. of Honolulu,

447 F.3d 1172

, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd 10 v. Gen. Motors Corp.,

307 F.3d 1206

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

187 F.R.D. 576, 577

(E.D. Wis. 1999) (even stipulated protective 12 orders require good cause showing), and a specific showing of good cause or 13 compelling reasons with proper evidentiary support and legal justification, must be 14 made with respect to Protected Material that a party seeks to file under seal. The 15 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL 16 does not—without the submission of competent evidence by declaration, 17 establishing that the material sought to be filed under seal qualifies as confidential, 18 privileged, or otherwise protectable—constitute good cause. 19 Further, if a party requests sealing related to a dispositive motion or trial, then 20 compelling reasons, not only good cause, for the sealing must be shown, and the 21 relief sought shall be narrowly tailored to serve the specific interest to be protected. 22 See Pintos v. Pac. Creditors Ass’n,

605 F.3d 665

, 677–79 (9th Cir. 2010). For each 23 item or type of information, document, or thing sought to be filed or introduced under 24 seal in connection with a dispositive motion or trial, the party seeking protection 25 must articulate compelling reasons, supported by specific facts and legal 26 justification, for the requested sealing order. Again, competent evidence supporting 27 the application to file documents under seal must be provided by declaration. 1 Any document that is not confidential, privileged, or otherwise protectable in 2 its entirety will not be filed under seal if the confidential portions can be redacted. 3 If documents can be redacted, then a redacted version for public viewing, omitting 4 only the confidential, privileged, or otherwise protectable portions of the document, 5 shall be filed. Any application that seeks to file documents under seal in their entirety 6 should include an explanation of why redaction is not feasible. 7 2. DEFINITIONS 8 2.1 Action: this pending federal lawsuit, Case No. 2:25-CV-07557-SSC. 9 2.2 Challenging Party: a Party or Non-Party that challenges the designation 10 of information or items under this Order. 11 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 12 how it is generated, stored or maintained) or tangible things that qualify for protection 13 under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified above in 14 the Good Cause Statement. 15 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 16 support staff). 17 2.5 Designating Party: a Party or Non-Party that designates information or 18 items that it produces in disclosures or in responses to discovery as 19 “CONFIDENTIAL.” 20 2.6 Disclosure or Discovery Material: all items or information, regardless of 21 the medium or manner in which it is generated, stored, or maintained (including, 22 among other things, testimony, transcripts, and tangible things), that are produced or 23 generated in disclosures or responses to discovery in this matter. 24 2.7 Expert: a person with specialized knowledge or experience in a matter 25 pertinent to the litigation who has been retained by a Party or its counsel to serve as 26 an expert witness or as a consultant in this Action. 27 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in 1 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of 2 this Action, including the time limits for filing any motions or applications for 3 extension of time pursuant to applicable law. 4 2.9 In-House Counsel: attorneys who are employees of a party to this Action. 5 In-House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 7 2.10 Non-Party: any natural person, partnership, corporation, association, or 8 other legal entity not named as a Party to this action. 9 2.11 Outside Counsel of Record: attorneys who are not employees of a party 10 to this Action but are retained to represent or advise a party to this Action and have 11 appeared in this Action on behalf of that party or are affiliated with a law firm which 12 has appeared on behalf of that party, and includes support staff. 13 2.12 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 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 2.14 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 2.15 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 25 from a Producing Party. 26 /// 27 /// 1 3. 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. This Stipulated Protective Order does not govern the use of Protected 9 Material at trial. 10 4. TRIAL AND DURATION 11 The terms of this Stipulated Protective Order apply through Final Disposition 12 of the Action. 13 Once a case proceeds to trial, information that was designated as 14 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and 15 used or introduced as an exhibit at trial becomes public and will be presumptively 16 available to all members of the public, including the press, unless compelling reasons 17 supported by specific factual findings to proceed otherwise are made to the trial judge 18 in advance of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 19 cause” showing for sealing documents produced in discovery from “compelling 20 reasons” standard when merits-related documents are part of court record). 21 Accordingly, for such materials, the terms of this Stipulated Protective Order do not 22 extend beyond the commencement of the trial. 23 5. DESIGNATING PROTECTED MATERIAL 24 5.1 Exercise of Restraint and Care in Designating Material for Protection. 25 Each Party or Non-Party that designates information or items for protection under this 26 Order must take care to limit any such designation to specific material that qualifies 27 under the appropriate standards. The Designating Party must designate for protection 1 qualify so that other portions of the material, documents, items, or communications 2 for which protection is not warranted are not swept unjustifiably within the ambit of 3 this Order. 4 Mass, indiscriminate, or routinized designations are prohibited. Designations 5 that are shown to be clearly unjustified or that have been made for an improper 6 purpose (e.g., to unnecessarily encumber the case development process or to impose 7 unnecessary expenses and burdens on other parties) may expose the Designating 8 Party to sanctions. 9 If it comes to a Designating Party’s attention that information or items that it 10 designated for protection do not qualify for protection, that Designating Party must 11 promptly notify all other Parties that it is withdrawing the inapplicable designation. 12 5.2 Manner and Timing of Designations. Except as otherwise provided in 13 this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below), 14 or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies 15 for protection under this Stipulated Protective Order must be clearly so designated 16 before the material is disclosed or produced. 17 Designation in conformity with this Stipulated Protective Order requires: 18 (a) for information in documentary form (e.g., paper or electronic 19 documents, but excluding transcripts of depositions or other pretrial or trial 20 proceedings), that the Producing Party affix at a minimum, the legend 21 “CONFIDENTIAL” to each page that contains protected material. If only a portion 22 or portions of the material on a page qualifies for protection, the Producing Party 23 also must clearly identify the protected portion(s) (e.g., by making appropriate 24 markings in the margins). 25 A Party or Non-Party that makes original documents available for inspection 26 need not designate them for protection until after the inspecting Party has indicated 27 which documents it would like copied and produced. During the inspection and 1 deemed CONFIDENTIAL. After the inspecting Party has identified the documents 2 it wants copied and produced, the Producing Party must determine which documents, 3 or portions thereof, qualify for protection under this Stipulated Protective Order. 4 Then, before producing the specified documents, the Producing Party must affix the 5 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 6 portion or portions of the material on a page qualifies for protection, the Producing 7 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 8 markings in the margins). 9 (b) for testimony given in depositions that the Designating Party identify 10 the Disclosure or Discovery Material on the record, before the close of the deposition 11 all protected testimony. 12 (c) for information produced in some form other than documentary and for 13 any other tangible items, that the Producing Party affix in a prominent place on the 14 exterior of the container or containers in which the information is stored the 15 “CONFIDENTIAL” legend. If only a portion or portions of the information warrants 16 protection, the Producing Party, to the extent practicable, shall identify the protected 17 portion(s). 18 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 19 failure to designate qualified information or items does not, standing alone, waive the 20 Designating Party’s right to secure protection under this Order for such material. 21 Upon timely correction of a designation, the Receiving Party must make reasonable 22 efforts to assure that the material is treated in accordance with the provisions of this 23 Stipulated Protective Order. 24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 26 designation of confidentiality at any time that is consistent with the court’s 27 Scheduling Order. 1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 2 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge 3 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”2 4 6.3 The burden of persuasion in any such challenge proceeding shall be on 5 the Designating Party. Frivolous challenges, and those made for an improper 6 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) 7 may expose the Challenging Party to sanctions. Unless the Designating Party has 8 waived or withdrawn the confidentiality designation, all parties shall continue to 9 afford the material in question the level of protection to which it is entitled under the 10 Producing Party’s designation until the court rules on the challenge. 11 7. ACCESS TO AND USE OF PROTECTED MATERIAL 12 7.1 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 reaches a Final Disposition, a 17 Receiving Party must comply with the provisions of section 13 below. 18 Protected Material must be stored and maintained by a Receiving Party at a 19 location and in a secure manner that ensures that access is limited to the persons 20 authorized under this Stipulated Protective Order. 21 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 22 otherwise ordered by the court or permitted in writing by the Designating Party, a 23 Receiving Party may disclose any information or item designated 24 “CONFIDENTIAL” only: 25 /// 26

27 2 Judge Christensen’s Procedures are available at 1 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as 2 well as employees of said Outside Counsel of Record to whom it is reasonably 3 necessary to disclose the information for this Action; 4 (b) to the officers, directors, and employees (including House Counsel) of 5 the Receiving Party to whom disclosure is reasonably necessary for this Action; 6 (c) to Experts (as defined in this Order) of the Receiving Party to whom 7 disclosure is reasonably necessary for this Action and who have signed the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (d) to the court and its personnel; 10 (e) to court reporters and their staff; 11 (f) to professional jury or trial consultants, mock jurors, and Professional 12 Vendors to whom disclosure is reasonably necessary for this Action and who have 13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (g) to the author or recipient of a document containing the information or a 15 custodian or other person who otherwise possessed or knew the information; 16 (h) during their depositions, to witnesses, and attorneys for witnesses, in the 17 Action to whom disclosure is reasonably necessary, provided: (1) the deposing party 18 requests that the witness sign the “Acknowledgment and Agreement to Be Bound” 19 (Exhibit A); and (2) the witness will not be permitted to keep any confidential 20 information unless they sign the “Acknowledgment and Agreement to Be Bound” 21 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the 22 court. Pages of transcribed deposition testimony or exhibits to depositions that reveal 23 Protected Material may be separately bound by the court reporter and may not be 24 disclosed to anyone except as permitted under this Stipulated Protective Order; and 25 (i) to any mediator or settlement officer, and their supporting personnel, 26 mutually agreed upon by any of the parties engaged in settlement discussions. 27 /// 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2 PRODUCED IN OTHER LITIGATION 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 shall 7 include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order 9 to issue in the other litigation that some or all of the material covered by the subpoena 10 or order is subject to this Protective Order. Such notification shall include a copy of 11 this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued 13 by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served 15 with the subpoena or court order shall not produce any information designated in this 16 action 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 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 23 PRODUCED IN THIS LITIGATION 24 9.1 Application. The terms of this Stipulated Protective Order are applicable 25 to information produced by a Non-Party in this Action and designated as 26 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with 27 this litigation is protected by the remedies and relief provided by this Order. Nothing 1 additional protections. 2 9.2 Notification. In the event that a Party is required, by a valid discovery 3 request, to produce a Non-Party’s confidential information in its possession, and the 4 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 5 confidential information, then the Party shall: 6 (a) promptly notify in writing the Requesting Party and the Non-Party that 7 some or all of the information requested is subject to a confidentiality agreement with 8 a Non-Party; 9 (b) make the information requested available for inspection by the Non- 10 Party, if requested. 11 9.3 Conditions of Production. If the Non-Party fails to seek a protective 12 order from this court within 14 days of receiving the notice and accompanying 13 information, the Receiving Party may produce the Non-Party’s confidential 14 information responsive to the discovery request. If the Non-Party timely seeks a 15 protective order, the Receiving Party shall not produce any information in its 16 possession or control that is subject to the confidentiality agreement with the Non- 17 Party before a determination by the court. Absent a court order to the contrary, the 18 Non-Party shall bear the burden and expense of seeking protection in this court of its 19 Protected Material. 20 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 21 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 22 Protected Material to any person or in any circumstance not authorized under this 23 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 24 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 25 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 26 persons to whom unauthorized disclosures were made of all the terms of this Order, 27 and (d) request such person or persons to execute the “Acknowledgment and 1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other protection, 5 the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the 6 Federal Rules of Civil Procedure. This provision is not intended to modify whatever 7 procedure may be established in an e-discovery order that provides for production 8 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules 9 of Evidence, insofar as the parties reach an agreement on the effect of disclosure of 10 a communication or information covered by the attorney-client privilege or work 11 product protection, the parties may incorporate their agreement in the stipulated 12 protective order submitted to the court. 13 12. MISCELLANEOUS 14 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 15 abridges the right of any person to seek its modification by the court in the future. 16 12.2 Right to Assert Other Objections. By stipulating to the entry of this 17 Stipulated Protective Order no Party waives any right it otherwise would have to 18 object to disclosing or producing any information or item on any ground not 19 addressed in this Stipulated Protective Order. Similarly, no Party waives any right 20 to object on any ground to use in evidence of any of the material covered by this 21 Stipulated Protective Order. 22 12.3 Filing Protected Material. A Party that seeks to file under seal any 23 Protected Material must comply with Local Rule 79-5. Protected Material may only 24 be filed under seal pursuant to a court order authorizing the sealing of the specific 25 Protected Material at issue. If a Party's request to file Protected Material under seal 26 is denied by the court, then the Receiving Party may file the information in the public 27 record unless otherwise instructed by the court. 1 13. FINAL DISPOSITION 2 After the Final Disposition of this Action, as defined in paragraph 4, within 3 60 days of a written request by the Designating Party, each Receiving Party must 4 return all Protected Material to the Producing Party or destroy such material. As 5 used in this subdivision, “all Protected Material” includes all copies, abstracts, 6 compilations, summaries, and any other format reproducing or capturing any of the 7 Protected Material. Whether the Protected Material is returned or destroyed, the 8 Receiving Party must submit a written certification to the Producing Party (and, if 9 not the same person or entity, to the Designating Party) by the 60 day deadline that 10 (1) identifies (by category, where appropriate) all the Protected Material that was 11 returned or destroyed and (2) affirms that the Receiving Party has not retained any 12 copies, abstracts, compilations, summaries or any other format reproducing or 13 capturing any of the Protected Material. Notwithstanding this provision, Counsel is 14 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, 15 and hearing transcripts, legal memoranda, correspondence, deposition and trial 16 exhibits, expert reports, attorney work product, and consultant and expert work 17 product, even if such materials contain Protected Material. Any such archival copies 18 that contain or constitute Protected Material remain subject to this Protective Order 19 as set forth in Section 4. 20 /// 21 /// 22 /// 23 24 25 26 27 1 || 14. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished by any and 3 || all appropriate measures including, without limitation, contempt proceedings and/or 4 |) monetary sanctions. 5 || ITISSO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 Dated: November 25, 2025 QUILL & ARROW, LLP 8 By: /s/ Long Cao 9 LONG CAO 10 Attorney for Plaintiff JUSTINE BONTIGAO 11 '? | Dated: November 25, 2025 SHOOK, HARDY & BACON □□□□□□ 3 By: /s/ Nelson X. Liu 14 AMIR NASSIHI BRADY R. O’BRYAN 15 KRISTINE AVENA 16 NELSON X. LIU 17 Attorneys for Defendant NISSAN NORTH AMERICA, INC. 18 19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 20 21 DATED: December 1, 2025 Z ~ 22 STEPHANIE S. CHRISTENSEN United States Magistrate Judge 23 24 25 26 27 28 15

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ________________________ [print or type full name], of 4 ________________________________________ [print or type full address], declare under penalty of perjury that I have read in its entirety and understand the 5 Stipulated Protective Order that was issued by the United States District Court for 6 the Central District of California on _________________ [date] in the case of 7 Justine Bontigao v. Nissan North America, Inc., Case No. 2:25-cv-07557-SSC. 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 to sanctions and punishment in the nature of contempt. I solemnly promise that I 10 will not disclose in any manner any information or item that is subject to this 11 Stipulated Protective Order to any person or entity except in strict compliance with 12 the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court 14 for the Central District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such enforcement proceedings occur after 15 termination of this action. I hereby appoint _____________________________ 16 [print or type full name] of ____________________________________ 17 __________________________________________________________________ 18 [print or type full address and telephone number] as my California agent for 19 service of process in connection with this action or any proceedings related to enforcement of this Stipulated Protective Order. 20

21 Date: ___________________________ 22 City and State where sworn and signed: ___________________________ 23 Printed name: ___________________________ 24 Signature: ___________________________

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