Yesenia Gallegos (SBN 231852) 1 ygallegos@mwe.com Ashley Attia (SBN 311779) 2 aattia@mwe.com

MCDERMOTT WILL & EMERY LLP

3 2049 Century Park East Suite 3200 4 Los Angeles, CA 90067-3206 Telephone: +1 310 277 4110 5 Facsimile: +1 310 277 4730

6 Attorneys for Defendants

BAXTER HEALTHCARE CORP., HILL-

7 ROM COMPANY, INC., AND JOSE

ALMEIDA

8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

10 11 JUSTIN HOPKINS, as an individual, CASE NO. 2:22-cv-05782-MWF-GJS Plaintiff, Magistrate Judge: Hon. Gail J. Standish 12 Courtroom: 640 v. 13 BAXTER HEALTHCARE CORP., a STIPULATED PROTECTIVE 14 Delaware Corporation; HILL-ROM ORDER COMPANY, INC., an Indiana 15 Corporation; JOSE ALMEIDA, as an Individual; and DOES 1 through 10, 16 inclusive, Complaint Filed: July 12, 2022 Removal Filed: 17 Defendants. Trial:

18 19 20 21 22 23 24 25 26 27 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 disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. 5 Accordingly, the parties hereby stipulate to and petition the Court to enter the 6 following Stipulated Protective Order. The parties acknowledge that this Order does 7 not confer blanket protections on all disclosures or responses to discovery and that 8 the protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable 10 legal principles. 11 B. GOOD CAUSE STATEMENT 12 In light of Plaintiff’s claims and allegations, the sales position that Plaintiff 13 held with Defendant Hillrom, which Defendant Baxter acquired in December 2021, 14 in what is a highly regulated industry (healthcare), this case and its discovery will 15 involve the production of records and information that is highly confidential 16 proprietary and/or tread secret or that contain confidential and private information 17 pertaining to third parties. In order to expedite the flow of information, to facilitate 18 the prompt resolution of disputes over confidentiality of discovery materials, to 19 adequately protect information the parties are entitled to keep confidential, to ensure 20 that the parties are permitted reasonable necessary uses of such material in 21 connection with this action, to address their handling of such material at the end of 22 the litigation, and to serve the ends of justice, a protective order for such information 23 is justified in this matter. The parties shall not designate any information/documents 24 as confidential without a good faith belief that such information/documents have 25 been maintained in a confidential, non-public manner, and that there is good cause or 26 a compelling reason why it should not be part of the public record of this case. 27 /// 1 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 2 The parties further acknowledge, as set forth in Section 12.3, below, that this 3 Stipulated Protective Order does not entitle them to file confidential information 4 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 5 the standards that will be applied when a party seeks permission from the court to file 6 material under seal. 7 There is a strong presumption that the public has a right of access to judicial 8 proceedings and records in civil cases. In connection with non-dispositive motions, 9 good cause must be shown to support a filing under seal. See Kamakana v. City and 10 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 11 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 12 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require 13 good cause showing), and a specific showing of good cause or compelling reasons 14 with proper evidentiary support and legal justification, must be made with respect to 15 Protected Material that a party seeks to file under seal. The parties’ mere designation 16 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 17 submission of competent evidence by declaration, establishing that the material 18 sought to be filed under seal qualifies as confidential, privileged, or otherwise 19 protectable—constitute good cause. 20 Further, if a party requests sealing related to a dispositive motion or trial, then 21 compelling reasons, not only good cause, for the sealing must be shown, and the 22 relief sought shall be narrowly tailored to serve the specific interest to be protected. 23 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 24 each item or type of information, document, or thing sought to be filed or introduced 25 under seal in connection with a dispositive motion or trial, the party seeking 26 protection must articulate compelling reasons, supported by specific facts and legal 27 1 justification, for the requested sealing order. Again, competent evidence supporting 2 the application to file documents under seal 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 only 6 the confidential, privileged, or otherwise protectable portions of the document, shall 7 be filed. Any application that seeks to file documents under seal in their entirety 8 should include an explanation of why redaction is not feasible. 9 2. DEFINITIONS 10 2.1 Action: The instant action: Justin Hopkins v. BAXTER HEALTHCARE 11 CORP.; HILL-ROM COMPANY, INC.; JOSE ALMEIDA; and DOES 1 through 10, 12 Case No. 2:22-cv-05782-MWF-GJS. 13 2.2 Challenging Party: A Party or Non-Party that challenges the 14 designation of information or items under this Order. 15 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 16 how it is generated, stored or maintained) or tangible things in the possession of a 17 Designating Party who believes in good faith that such Information is entitled to 18 confidential treatment under applicable law or that qualify for protection under 19 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 22 their 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 27 of the medium or manner in which it is generated, stored, or maintained (including, 1 among other things, testimony, transcripts, and tangible things), that are produced or 2 generated in disclosures or responses to discovery in this matter. 3 2.7 Expert: a person with specialized knowledge or experience in a matter 4 pertinent to the litigation who has been retained by a Party or its counsel to serve as 5 an expert witness or as a consultant in this Action. 6 2.8 House Counsel: attorneys who are employees of a party to this Action. 7 House Counsel does not include Outside Counsel of Record or any other outside 8 counsel. 9 2.9 Non-Party: any natural person, partnership, corporation, association or 10 other legal entity not named as a Party to this action. 11 2.10 Outside Counsel of Record: attorneys who are not employees of a party 12 to this Action but are retained to represent or advise a party to this Action and have 13 appeared in this Action on behalf of that party or are affiliated with a law firm that 14 has appeared on behalf of that party, and includes support staff. 15 2.11 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 19 Discovery Material in this Action. 20 2.13 Professional Vendors: persons or entities that provide litigation support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) 23 and their employees and subcontractors. 24 2.14 Protected Material: any Disclosure or Discovery Material that is 25 designated as “CONFIDENTIAL.” 26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 27 from a Producing Party. 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 Order does not govern the use of Protected Material at trial. 9 4. DURATION 10 FINAL DISPOSITION of the action is defined as the conclusion of any 11 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 12 has run. Except as set forth below, the terms of this protective order apply through 13 FINAL DISPOSITION of the action. The parties may stipulate that the they will be 14 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 15 but will have to file a separate action for enforcement of the agreement once all 16 proceedings in this case are complete. 17 Once a case proceeds to trial, information that was designated as 18 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 19 as an exhibit at trial becomes public and will be presumptively available to all 20 members of the public, including the press, unless compelling reasons supported by 21 specific factual findings to proceed otherwise are made to the trial judge in advance 22 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 23 showing for sealing documents produced in discovery from “compelling reasons” 24 standard when merits-related documents are part of court record). Accordingly, for 25 such materials, the terms of this protective order do not extend beyond the 26 commencement of the trial. 27 /// 1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for Protection. 3 Each Party or Non-Party that designates information or items for protection under 4 this Order must take care to limit any such designation to specific material that 5 qualifies under the appropriate standards. The Designating Party must designate for 6 protection only those parts of material, documents, items or oral or written 7 communications that qualify so that other portions of the material, documents, items 8 or communications for which protection is not warranted are not swept unjustifiably 9 within the ambit of this Order. 10 Mass, indiscriminate or routinized designations are prohibited. Designations 11 that are shown to be clearly unjustified or that have been made for an improper 12 purpose (e.g., to unnecessarily encumber the case development process or to impose 13 unnecessary expenses and burdens on other parties) may expose the Designating 14 Party to sanctions. 15 If it comes to a Designating Party’s attention that information or items that it 16 designated for protection do not qualify for protection, that Designating Party must 17 promptly notify all other Parties that it is withdrawing the inapplicable designation. 18 5.2 Manner and Timing of Designations. Except as otherwise provided in 19 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 21 under this Order must be clearly so designated before the material is disclosed or 22 produced. 23 Designation in conformity with this Order requires: 24 (a) for information in documentary form (e.g., paper or electronic documents, 25 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 26 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 27 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 1 portion of the material on a page qualifies for protection, the Producing Party also 2 must clearly identify the protected portion(s) (e.g., by making appropriate markings 3 in the margins). 4 A Party or Non-Party that makes original documents available for inspection 5 need not designate them for protection until after the inspecting Party has indicated 6 which documents it would like copied and produced. During the inspection and 7 before the designation, all of the material made available for inspection shall be 8 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 9 documents it wants copied and produced, the Producing Party must determine which 10 documents, or portions thereof, qualify for protection under this Order. Then, before 11 producing the specified documents, the Producing Party must affix the 12 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 13 portion of the material on a page qualifies for protection, the Producing Party also 14 must clearly identify the protected portion(s) (e.g., by making appropriate markings 15 in the margins). 16 (b) for testimony given in depositions that the Designating Party identifies the 17 Disclosure or Discovery Material on the record, before the close of the deposition all 18 protected testimony. 19 (c) for information produced in some form other than documentary and for 20 any other tangible items, that the Producing Party affix in a prominent place on the 21 exterior of the container or containers in which the information is stored the legend 22 “CONFIDENTIAL.” If only a portion or portions of the information warrants 23 protection, the Producing Party, to the extent practicable, shall identify the protected 24 portion(s). 25 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 26 failure to designate qualified information or items does not, standing alone, waive the 27 Designating Party’s right to secure protection under this Order for such material. 1 Upon timely correction of a designation, the Receiving Party must make reasonable 2 efforts to assure that the material is treated in accordance with the provisions of this 3 Order. 4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 5 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 6 designation of confidentiality at any time that is consistent with the Court’s 7 Scheduling Order. 8 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 9 resolution process under Local Rule 37.1 et seq. 10 6.3 The burden of persuasion in any such challenge proceeding shall be on 11 the Designating Party. Frivolous challenges, and those made for an improper 12 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 13 parties) may expose the Challenging Party to sanctions. Unless the Designating 14 Party has waived or withdrawn the confidentiality designation, all parties shall 15 continue to afford the material in question the level of protection to which it is 16 entitled under the Producing Party’s designation until the Court rules on the 17 challenge. 18 7. ACCESS TO AND USE OF PROTECTED MATERIAL 19 7.1 Basic Principles. A Receiving Party may use Protected Material that is 20 disclosed or produced by another Party or by a Non-Party in connection with this 21 Action only for prosecuting, defending or attempting to settle this Action. Such 22 Protected Material may be disclosed only to the categories of persons and under the 23 conditions described in this Order. When the Action has been terminated, a 24 Receiving Party must comply with the provisions of section 13 below (FINAL 25 DISPOSITION). 26 /// 27 /// 1 Protected Material must be stored and maintained by a Receiving Party at a location 2 and in a secure manner that ensures that access is limited to the persons authorized 3 under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 5 otherwise ordered by the court or permitted in writing by the Designating Party, a 6 Receiving Party may disclose any information or item designated 7 “CONFIDENTIAL” only to: 8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 9 employees of said Outside Counsel of Record to whom it is reasonably necessary to 10 disclose the information for this Action; 11 (b) the officers, directors, and employees (including House Counsel) of the 12 Receiving Party to whom disclosure is reasonably necessary for this Action; 13 (c) Experts (as defined in this Order) of the Receiving Party to whom 14 disclosure is reasonably necessary for this Action and who have signed the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (d) the court and its personnel; 17 (e) court reporters and their staff; 18 (f) professional jury or trial consultants, mock jurors, and Professional 19 Vendors to whom disclosure is reasonably necessary for this Action and who have 20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (g) the author or recipient of a document containing the information or a 22 custodian or other person who otherwise possessed or knew the information; 23 (h) during their depositions, witnesses, and attorneys for witnesses, in the 24 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 25 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 26 not be permitted to keep any confidential information unless they sign the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 1 agreed by the Designating Party or ordered by the court. Pages of transcribed 2 deposition testimony or exhibits to depositions that reveal Protected Material may be 3 separately bound by the court reporter and may not be disclosed to anyone except as 4 permitted under this Stipulated Protective Order; and 5 (i) any mediator or settlement officer, and their supporting personnel, 6 mutually agreed upon by any of the parties engaged in settlement discussions. 7 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 8 PRODUCED IN OTHER LITIGATION 9 If a Party is served with a subpoena or a court order issued in other litigation 10 that compels disclosure of any information or items designated in this Action as 11 “CONFIDENTIAL,” that Party must: 12 (a) promptly notify in writing the Designating Party. Such notification shall 13 include a copy of the subpoena or court order; 14 (b) promptly notify in writing the party who caused the subpoena or order to 15 issue in the other litigation that some or all of the material covered by the subpoena 16 or order is subject to this Protective Order. Such notification shall include a copy of 17 this Stipulated Protective Order; and 18 (c) cooperate with respect to all reasonable procedures sought to be pursued 19 by the Designating Party whose Protected Material may be affected. 20 If the Designating Party timely seeks a protective order, the Party served with 21 the subpoena or court order shall not produce any information designated in this 22 action as “CONFIDENTIAL” before a determination by the court from which the 23 subpoena or order issued, unless the Party has obtained the Designating Party’s 24 permission. The Designating Party shall bear the burden and expense of seeking 25 protection in that court of its confidential material and nothing in these provisions 26 should be construed as authorizing or encouraging a Receiving Party in this Action to 27 disobey a lawful directive from another court. 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a Non- 4 Party in this Action and designated as “CONFIDENTIAL.” Such information 5 produced by Non-Parties in connection with this litigation is protected by the 6 remedies and relief provided by this Order. Nothing in these provisions should be 7 construed as prohibiting a Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to 9 produce a Non-Party’s confidential information in its possession, and the Party is 10 subject to an agreement with the Non-Party not to produce the Non-Party’s 11 confidential information, then the Party shall: 12 (1) promptly notify in writing the Requesting Party and the Non-Party that 13 some or all of the information requested is subject to a confidentiality agreement 14 with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 16 Order in this Action, the relevant discovery request(s), and a reasonably specific 17 description of the information requested; and 18 (3) make the information requested available for inspection by the Non-Party, 19 if requested. 20 (c) If the Non-Party fails to seek a protective order from this court within 14 21 days of receiving the notice and accompanying information, the Receiving Party may 22 produce the Non-Party’s confidential information responsive to the discovery 23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 24 not produce any information in its possession or control that is subject to the 25 confidentiality agreement with the Non-Party before a determination by the court. 26 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 27 of seeking protection in this court of its Protected Material. 1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 7 persons to whom unauthorized disclosures were made of all the terms of this Order, 8 and (d) request such person or persons to execute the “Acknowledgment and 9 Agreement to Be Bound” that is attached hereto as Exhibit A. 10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 11 PROTECTED MATERIAL 12 When a Producing Party gives notice to Receiving Parties that certain 13 inadvertently produced material is subject to a claim of privilege or other protection, 14 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 15 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 16 may be established in an e-discovery order that provides for production without prior 17 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 18 parties reach an agreement on the effect of disclosure of a communication or 19 information covered by the attorney-client privilege or work product protection, the 20 parties may incorporate their agreement in the stipulated protective order submitted 21 to the court. 22 12. MISCELLANEOUS 23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 24 person to seek its modification by the Court in the future. 25 12.2 Right to Assert Other Objections. By stipulating to the entry of this 26 Protective Order, no Party waives any right it otherwise would have to object to 27 disclosing or producing any information or item on any ground not addressed in this 1 Stipulated Protective Order. Similarly, no Party waives any right to object on any 2 ground to use in evidence of any of the material covered by this Protective Order. 3 12.3 Filing Protected Material. A Party that seeks to file under seal any 4 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 5 only be filed under seal pursuant to a court order authorizing the sealing of the 6 specific Protected Material at issue. If a Party’s request to file Protected Material 7 under seal is denied by the court, then the Receiving Party may file the information 8 in the public record unless otherwise instructed by the court. 9 13. FINAL DISPOSITION 10 After the final disposition of this Action, as defined in paragraph 4, within 60 11 days of a written request by the Designating Party, each Receiving Party must return 12 all Protected Material to the Producing Party or destroy such material. As used in 13 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 14 summaries, and any other format reproducing or capturing any of the Protected 15 Material. Whether the Protected Material is returned or destroyed, the Receiving 16 Party must submit a written certification to the Producing Party (and, if not the same 17 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 18 (by category, where appropriate) all the Protected Material that was returned or 19 destroyed and (2) affirms that the Receiving Party has not retained any copies, 20 abstracts, compilations, summaries or any other format reproducing or capturing any 21 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 22 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 23 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 24 reports, attorney work product, and consultant and expert work product, even if such 25 materials contain Protected Material. Any such archival copies that contain or 26 constitute Protected Material remain subject to this Protective Order as set forth in 27 Section 4 (DURATION). 1 14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 including, without limitation, contempt proceedings and/or monetary sanctions. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 Dated: __A_p_r_il_ _1_3_, 2023 Respectfully submitted, 7 MCDERMOTT WILL & EMERY LLP 8 By: /s/ Yesenia Gallegos 9

YESENIA GALLEGOS

10 ASHLEY ATTIA Attorneys for Defendants 11

BAXTER HEALTHCARE CORP.,

12 HILL-ROM COMPANY, INC. 13

WEST COAST EMPLOYMENT

Dated: _0_2_/2_7_/__, 2023 14 LAWYERS, APLC BY: Nick Yas man /s / 15 Ronald L. Zambrano, Esq. 16 Nicholas A. Yasman, Esq. Attorneys for Plaintiffs, 17

JUSTIN HOPKINS

18 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 20

DATED: __4_/1_3_/_2_3____ /S/ CHARLES F. EICK

21

HON. CHARLES F. EICK

22 United States Magistrate Judge 23 24 25 26 27 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 Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on [date] in the case of Justin Hopkins v. BAXTER HEALTHCARE CORP.; HILL- 9 ROM COMPANY, INC.; JOSE ALMEIDA; and DOES 1 through 10, Case No. 2:22- 10 cv-05782-MWF-GJS. I agree to comply with and to be bound by all the terms of this 11 Stipulated Protective Order and I understand and acknowledge that failure to so 12 comply could expose me to sanctions and punishment in the nature of contempt. I 13 solemnly promise that I will not disclose in any manner any information or item that 14 is subject to this Stipulated Protective Order to any person or entity except in strict 15 compliance with the provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court for the 17 Central District of California for enforcing the terms of this Stipulated Protective 18 Order, even if such enforcement proceedings occur after termination of this action. I 19 hereby appoint __________________________ [print or type full name] of 20 _______________________________________ [print or type full address and 21 telephone number] as my California agent for service of process in connection with 22 this action or any proceedings related to enforcement of this Stipulated Protective 23 Order. 24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________