1 MBROIRAGNA CN. ,F LREOWNITSI N&O B (OSCtaKteI UBaSr LNLoP. 222032) 2049 Century Park East, Suite 700 2 Los Angeles, CA 90067 Telephone: 310.907.1000 3 Facsimile: 310.907.1001 Email: brian.frontino@morganlewis.com 4 Attorneys for Defendant 5 AMERICAN EXPRESS NATIONAL BANK, erroneously sued as AMERICAN EXPRESS 6 COMPANY 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 LA TECH AND CONSULTING, LLC, a ) C ase No. 8:22-cv-01213-DOC-KES California Limited Liability Company, ) ) 12 Plaintiff, )

ORDER RE STIPULATED

PROTECTIVE ORDER

13 ) vs. ) 14 ) AMERICAN EXPRESS COMPANY, a ) New York Corporation; and DOES 1 to 15 ) 50, inclusive, ) 16 Defendants. ) ) 17 ) ) 18 ) 19 ) ) 20 21 22 23 24 25 26 27 28 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may be 5 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 6 the following Stipulated Protective Order. The parties acknowledge that this Order 7 does not confer blanket protections on all disclosures or responses to discovery and 8 that the protection it affords from public disclosure and use extends only to the 9 limited information or items that are entitled to confidential treatment under the 10 applicable legal principles. The parties further acknowledge, as set forth in Section 11 12.3, below, that this Stipulated Protective Order does not entitle them to file 12 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures 13 that must be followed and the standards that will be applied when a party seeks 14 permission from the court to file material under seal. 15 B. GOOD CAUSE STATEMENT 16 This action is likely to involve trade secrets, private financial information and 17 records, and other valuable research, development, commercial, financial, technical 18 and/or proprietary information for which special protection from public disclosure 19 and from use for any purpose other than prosecution of this action is warranted. 20 Such confidential and proprietary materials and information consist of, among other 21 things, confidential business or financial information, information regarding 22 confidential business practices, financial records and account information (including 23 records and information implicating privacy rights of third parties), or information 24 otherwise generally unavailable to the public, or which may be privileged or 25 otherwise protected from disclosure under state or federal statutes, court rules, case 26 decisions, or common law. Accordingly, to expedite the flow of information, to 27 facilitate the prompt resolution of disputes over confidentiality of discovery 28 materials, to adequately protect information the parties are entitled to keep 1 confidential, to ensure that the parties are permitted reasonable necessary uses of 2 such material in preparation for and in the conduct of trial, to address their handling 3 at the end of the litigation, and to serve the ends of justice, a protective order for such 4 information is justified in this matter. It is the intent of the parties that information 5 will not be designated as confidential for tactical reasons and that nothing be so 6 designated without a good faith belief that it has been maintained in a confidential, 7 non-public manner, and there is good cause why it should not be part of the public 8 record of this case. 9 2. DEFINITIONS 10 2.1 Action: this pending federal lawsuit, captioned LA Tech and Consulting, 11 LLC v. American Express Company, Case No. 8:22-cv-01213-DOC-KES. 12 2.2 Challenging Party: a Party or Non-Party that challenges the designation 13 of information or items under this Order. 14 2.3 “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 the 17 Good Cause Statement. 18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 19 their support staff). 20 2.5 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 2.6 Disclosure or Discovery Material: all items or information, regardless of 24 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 in this matter. 27 28 1 2.7 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 2.8 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 2.9 Non-Party: any natural person, partnership, corporation, association, or 8 other legal entity not named as a Party to this action. 9 2.10 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 2.11 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, House Counsel, and Outside Counsel of 15 Record (and their support staffs). 16 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 2.13 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 2.14 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL”. 24 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 25 from a Producing Party. 26 3. SCOPE 27 The protections conferred by this Stipulation and Order cover not only 28 Protected Material (as defined above), but also (1) any information copied or 1 extracted from Protected Material; (2) all copies, excerpts, summaries, or 2 compilations of Protected Material; and (3) any testimony, conversations, or 3 presentations by Parties or their Counsel that might reveal Protected Material. 4 Any use of Protected Material at trial shall be governed by the orders of the 5 trial judge. This Order does not govern the use of Protected Material at trial. 6 4. DURATION 7 Even after final disposition of this litigation, the confidentiality obligations 8 imposed by this Order shall remain in effect until a Designating Party agrees 9 otherwise in writing or a court order otherwise directs. Final disposition shall be 10 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 11 or without prejudice; and (2) final judgment herein after the completion and 12 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 13 including the time limits for filing any motions or applications for extension of time 14 pursuant to applicable law. 15 5. DESIGNATING PROTECTED MATERIAL 16 5.1 Exercise of Restraint and Care in Designating Material for Protection. 17 Each Party or Non-Party that designates information or items for protection 18 under this Order must take care to limit any such designation to specific material that 19 qualifies under the appropriate standards. The Designating Party must designate for 20 protection only those parts of material, documents, items, or oral or written 21 communications that qualify so that other portions of the material, documents, items, 22 communications for which protection is not warranted are not swept unjustifiably 23 within the ambit of this Order. 24 Mass, indiscriminate, or routinized designations are prohibited. Designations 25 that are shown to be clearly unjustified or that have been made for an improper 26 purpose (e.g., to unnecessarily encumber the case development process or to impose 27 unnecessary expenses and burdens on other parties) may expose the Designating 28 Party to sanctions. 1 If it comes to a Designating Party’s attention that information or items that it 2 designated for protection do not qualify for protection, that Designating Party must 3 promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2 Manner and Timing of Designations. Except as otherwise provided in 5 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 7 under this Order must be clearly so designated before the material is disclosed or 8 produced. 9 Designation in conformity with this Order requires: 10 (a) for information in documentary form (e.g., paper or electronic 11 documents, but excluding transcripts of depositions or other pretrial or trial 12 proceedings), that the Producing Party affix at a minimum, the legend 13 “CONFIDENTIAL”, to each page that contains protected material. If only a portion 14 or portions of the material on a page qualifies for protection, the Producing Party also 15 must clearly identify the protected portion(s) (e.g., by making appropriate markings 16 in the margins). 17 A Party or Non-Party that makes original documents available for inspection 18 need not designate them for protection until after the inspecting Party has indicated 19 which documents it would like copied and produced. During the inspection and 20 before the designation, all of the material made available for inspection shall be 21 deemed “CONFIDENTIAL”. After the inspecting Party has identified the 22 documents it wants copied and produced, the Producing Party must determine which 23 documents, or portions thereof, qualify for protection under this Order. Then, before 24 producing the specified documents, the Producing Party must affix the legend 25 “CONFIDENTIAL” to each page that contains Protected Material. If only a portion 26 or portions of the material on a page qualifies for protection, the Producing Party also 27 must clearly identify the protected portion(s) (e.g., by making appropriate markings 28 in the margins). 1 (b) for testimony given in depositions, the entire transcript shall be 2 treated as Protected Material for thirty (30) days following receipt by all Parties of 3 the transcript. By default during this period, the entire transcript will be treated as 4 CONFIDENTIAL, unless a Party designates it at a higher level of confidentiality 5 before the close of the deposition. Any Party wishing to designate portions of the 6 transcript or the exhibits attached thereto as Protected Material must do so within 7 those thirty (30) days. 8 (c) for information produced in some form other than documentary 9 and for any other tangible items, that the Producing Party affix in a prominent place 10 on the exterior of the container or containers in which the information is stored the 11 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants 12 protection, the Producing Party, to the extent practicable, shall identify the protected 13 portion(s). 14 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 15 failure to designate qualified information or items does not, standing alone, waive the 16 Designating Party’s right to secure protection under this Order for such material. 17 Upon timely correction of a designation, the Receiving Party must make reasonable 18 efforts to assure that the material is treated in accordance with the provisions of this 19 Order. 20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 21 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 22 designation of confidentiality at any time that is consistent with the Court’s 23 Scheduling Order. 24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 25 resolution process under Local Rule 37-1 et seq. or follow the procedures for 26 informal, telephonic discovery hearings on the Court’s website. 27 6.3 The burden of persuasion in any such challenge proceeding shall be on 28 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 7. ACCESS TO AND USE OF PROTECTED MATERIAL 8 7.1 Basic Principles. A Receiving Party may use Protected Material that is 9 disclosed or produced by another Party or by a Non-Party in connection with this 10 Action only for prosecuting, defending, or attempting to settle this Action. Such 11 Protected Material may be disclosed only to the categories of persons and under the 12 conditions described in this Order. When the Action has been terminated, a 13 Receiving Party must comply with the provisions of section 13 below (FINAL 14 DISPOSITION). 15 Protected Material must be stored and maintained by a Receiving Party at a 16 location and in a secure manner that ensures that access is limited to the persons 17 authorized under this Stipulated Protective Order. 18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 19 otherwise ordered by the court or permitted in writing by the Designating Party, a 20 Receiving Party may disclose any information or item designated 21 “CONFIDENTIAL” only to: 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, 23 as well as employees of said Outside Counsel of Record to whom it is reasonably 24 necessary to disclose the information for this Action; 25 (b) the officers, directors, and employees (including House Counsel) 26 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 27 28 1 (c) Experts (as defined in this Order) of the Receiving Party to whom 2 disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (d) the court and its personnel; 5 (e) court reporters and their staff; 6 (f) professional jury or trial consultants, mock jurors, and 7 Professional Vendors to whom disclosure is reasonably necessary for this Action and 8 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (g) the author or recipient of a document containing the information 10 or a custodian or other person who otherwise possessed or knew the information; 11 (h) during their depositions, witnesses ,and attorneys for witnesses, in 12 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 13 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 14 they will not be permitted to keep any confidential information unless they sign the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 16 agreed by the Designating Party or ordered by the court. Pages of transcribed 17 deposition testimony or exhibits to depositions that reveal Protected Material may be 18 separately bound by the court reporter and may not be disclosed to anyone except as 19 permitted under this Stipulated Protective Order; and 20 (i) any mediator or settlement officer, and their supporting 21 personnel, mutually agreed upon by any of the parties engaged in settlement 22 discussions. 23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 24 PRODUCED IN OTHER LITIGATION 25 If a Party is served with a subpoena or a court order issued in other litigation 26 that compels disclosure of any information or items designated in this Action as 27 “CONFIDENTIAL,” that Party must: 28 1 (a) promptly notify in writing the Designating Party. Such 2 notification shall include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or 4 order to issue in the other litigation that some or all of the material covered by the 5 subpoena or order is subject to this Protective Order. Such notification shall include 6 a copy of this Stipulated Protective Order; and 7 (c) cooperate with respect to all reasonable procedures sought to be 8 pursued by the Designating Party whose Protected Material may be affected. 9 If the Designating Party timely seeks a protective order, the Party served with 10 the subpoena or court order shall not produce any information designated in this 11 action as “CONFIDENTIAL” before a determination by the court from which the 12 subpoena or order issued, unless the Party has obtained the Designating Party’s 13 permission. The Designating Party shall bear the burden and expense of seeking 14 protection in that court of its confidential material and nothing in these provisions 15 should be construed as authorizing or encouraging a Receiving Party in this Action to 16 disobey a lawful directive from another court. 17 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 18 PRODUCED IN THIS LITIGATION 19 (a) The terms of this Order are applicable to information produced by 20 a Non-Party in this Action and designated as Protected Material. Such information 21 produced by Non-Parties in connection with this litigation is protected by the 22 remedies and relief provided by this Order. Nothing in these provisions should be 23 construed as prohibiting a Non-Party from seeking additional protections. 24 (b) In the event that a Party is required, by a valid discovery request, 25 to produce a Non-Party’s confidential information in its possession, and the Party is 26 subject to an agreement with the Non-Party not to produce the Non-Party’s 27 confidential information, then the Party shall: 28 1 (1) promptly notify in writing the Requesting Party and the 2 Non-Party that some or all of the information requested is subject to a confidentiality 3 agreement with a Non-Party; 4 (2) promptly provide the Non-Party with a copy of the 5 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 6 reasonably specific description of the information requested; and 7 (3) make the information requested available for inspection by 8 the Non-Party, if requested. 9 (c) If the Non-Party fails to seek a protective order from this court 10 within fourteen (14) days of receiving the notice and accompanying information, the 11 Receiving Party may produce the Non-Party’s confidential information responsive to 12 the discovery request. If the Non-Party timely seeks a protective order, the 13 Receiving Party shall not produce any information in its possession or control that is 14 subject to the confidentiality agreement with the Non-Party before a determination 15 by the court. Absent a court order to the contrary, the Non-Party shall bear the 16 burden and expense of seeking protection in this court of its Protected Material. 17 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 18 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 19 Protected Material to any person or in any circumstance not authorized under this 20 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 21 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 22 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 23 persons to whom unauthorized disclosures were made of all the terms of this Order, 24 and (d) request such person or persons to execute the “Acknowledgment and 25 Agreement to Be Bound” that is attached hereto as Exhibit A. 26 27 28 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 Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 7 may be established in an e-discovery order that provides for production without prior 8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 9 parties reach an agreement on the effect of disclosure of a communication or 10 information covered by the attorney-client privilege or work product protection, the 11 parties may incorporate their agreement in a stipulated protective order submitted to 12 the court. 13 12. MISCELLANEOUS 14 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 15 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 Order no Party waives any right it otherwise would have to object to disclosing or 18 producing any information or item on any ground not addressed in this Stipulated 19 Protective Order. Similarly, no Party waives any right to object on any ground to use 20 in evidence of any of the material covered by this Order. 21 12.3 Filing Protected Material. A Party that seeks to file under seal any 22 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 23 only be filed under seal pursuant to a court order authorizing the sealing of the 24 specific Protected Material at issue. If a Party’s request to file Protected Material 25 under seal is denied by the court, then the Receiving Party may file the information 26 in the public record unless otherwise instructed by the court. 27 12.4 Production of Third-Party Confidential Account Information. The 28 parties acknowledge that this action concerns non-public, private and confidential 1 American Express Card account information of third parties. Those third parties 2 have a legitimate expectation and/or right of privacy in their personal, non-public, 3 financial information represented on American Express card account statements 4 pursuant to constitution, statute, such as the Gramm-Leach-Bliley Act, 15 U.S.C. § 5 6801, et seq., and 12 C.F.R. Part 1016 et seq. (“GLBA”), and the Fair and Accurate 6 Credit Transactions Act, 15 U.S.C. § 1601 et seq., and/or case law, such as Marks v. 7 Global Mortgage Group, Inc., 218 F.R.D. 492, 497 (S.D. W. Va. 2003) (“Congress 8 has expressed a strong interest in protecting the privacy of consumers’ financial 9 information.”); Davis v. Leal, 43 F. Supp. 2d 1102, 1111 (E.D. Cal. 1999) (finding 10 information that implicates private financial information is “presumptively 11 privileged”); In re Crawford, 194 F.3d 954, 958-59 (9th Cir. 1999) (noting that the 12 existence of a constitutionally protected “zone of privacy” is firmly established by 13 the Supreme Court). Indeed, under the GLBA, American Express is prohibited from 14 “disclos[ing] to a nonaffiliated third party any nonpublic personal information” 15 relating to its customers, unless an exception to GLBA applies. 15 U.S.C. § 6802(a). 16 “Personally identifiable financial information” means any information, in the context 17 of the provision of a financial product or service, that (1) a consumer gives to a 18 financial institution, (2) is about a consumer’s transaction, or (3) a financial 19 institution obtains from a consumer. 16 C.F.R. § 313.3(o)(1); see also 15 U.S.C. § 20 6809(4)(A)(i)-(iii). Even the fact that an individual is or has been the customer of a 21 financial institution constitutes “personally identifiable financial information” under 22 GLBA’s implementing regulation. See 16 C.F.R. § 313(o). Through entry of this 23 Order, American Express is permitted to disclose all such records relating to the 24 American Express card accounts to which payments at issue in this action were 25 made, notwithstanding that those account records contain information in which third 26 parties may have a legitimate expectation and/or right of privacy pursuant to federal 27 and state constitutions, statute or case law. 28 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in Section 4, within sixty 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 used 5 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 are 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 (DURATION). 20 14. Any violation of this Stipulated Order may be punished by any and all 21 appropriate measures including, without limitation, contempt proceedings and/or 22 monetary sanctions. 23 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 24 25 26 27 28 1 Dated: June 7, 2024 MORGAN, LEWIS & BOCKIUS LLP 2 BRIAN C. FRONTINO 3 By: /s/ Brian C. Frontino 4 Brian C. Frontino 5 Attorneys for Defendant 6 AMERICAN EXPRESS NATIONAL BANK, erroneously sued as 7

AMERICAN EXPRESS COMPANY

8 9 10 Dated: June 7, 2024 DAILY LAW GROUP 11 JAMES D. DAILY 12 By: /s/ James D. Daily 13 James D. Daily 14 Attorneys for Plaintiff 15 LA TECH AND CONSULTING, LLC 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Certification of Compliance with C.D. Cal. L.R. 5-4.3.4(a)(2)(i) 2 Pursuant to Local Rule 5-4.3.4(a)(2)(1i), the filer of this document attests that 3 || concurrence in the filing of the document has been obtained from each of the other 4 || Signatories. 5 6 /s/ Brian C. Frontino 4 Brian C. Frontino 8 9 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 10 Dated: June 10, 2024 Tans & S □□□ Hon. KarenE. Scott United States Magistrate Judge 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -16- At LAw □□ OTTDOT ATELY) PROTECTIVE □□□□□□□

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 5 entirety and understand the Stipulated Protective Order that was issued by the United 6 States District Court for the Central District of California on _____________ [date] 7 in the case of LA Tech and Consulting, LLC v. American Express Company, Case 8 No. 8:22-cv-01213-DOC-KES. I agree to comply with and to be bound by all the 9 terms of this Stipulated Protective Order and I understand and acknowledge that 10 failure to so comply could expose me to sanctions and punishment in the nature of 11 contempt. I solemnly promise that I will not disclose in any manner any information 12 or item that is subject to this Stipulated Protective Order to any person or entity 13 except in strict compliance with the provisions 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 type 18 full name] of _____________________________________________________ 19 [print or type full address and telephone number] as my California agent for service 20 of process in connection with this action or any proceedings related to enforcement 21 of this Stipulated Protective Order. 22 Date: _________________________ 23 City and State where sworn and signed: ___________________________________ 24 Printed name: _____________________________ 25 Signature: ________________________________