1 JEULNISEE T O. ’MBORINERNO, EC,A CSAta Steta Btea Br Naro N. 2o4. 5298647763 2

RYNN & JANOWSKY, LLP

3 4100 Newport Place Drive, Suite 700 Newport Beach, CA 92660 4 T: 949.752.2911

F: 949.752.0953

5 elise@rjlaw.com 6 june@rjlaw.com 7 PHILLIP RAY, NJ State Bar No. 039692002 8 KLUGER HEALEY, LLC 106 Apple Street, Suite 302 9 Tinton Falls, NJ 07724

T: 732.852.7500

10

F: 888.635.1653

11 pray@klugherhealey.com 12 Attorneys for Defendant MAGNET MEDIA, INC. 13

UNITED STATES DISTRICT COURT

14

FOR THE CENTRAL DISTRICT OF CALIFORNIA

15 16 DAVID BRASHEAR, individually, and CASE NO. 2:17-CV-06026-AB-AFM on behalf of all others similarly situated, 17

STIPULATED

18 Plaintiff, CONFIDENTIALITY

AGREEMENT AND [PROPOSED]

19 v. PROTECTIVE ORDER 20 MAGNET MEDIA, INC., a New York 21 corporation, COMPLEX MEDIA, INC., a Delaware Corporation, 22 23 Defendants. 24 25 26 27 28 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action are likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 5 disclosure and from use for any purpose other than prosecuting this litigation may 6 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 7 enter the following Stipulated Protective Order. The parties acknowledge that this 8 9 Order does not confer blanket protections on all disclosures or responses to 10 discovery and that the protection it affords from public disclosure and use extends 11 only to the limited information or items that are entitled to confidential treatment 12 13 under the applicable legal principles. 14

B. GOOD CAUSE STATEMENT

15 This action is likely to involve customer and pricing lists and other valuable 16 17 research, development, commercial, financial, technical and/or proprietary 18 information for which special protection from public disclosure and from use for 19 20 any purpose other than prosecution of this action is warranted. Such confidential 21 and proprietary materials and information consist of, among other things, 22 confidential business or financial information, information regarding confidential 23 24 business practices, or other confidential research, development, or commercial 25 information (including information implicating privacy rights of third parties), 26 information otherwise generally unavailable to the public, or which may be 27 28 privileged or otherwise protected from disclosure under state or federal statutes, 1 court rules, case decisions, or common law. Accordingly, to expedite the flow of 2 information, to facilitate the prompt resolution of disputes over confidentiality of 3 discovery materials, to adequately protect information the parties are entitled to 4 5 keep confidential, to ensure that the parties are permitted reasonable necessary uses 6 of such material in preparation for and in the conduct of trial, to address their 7 handling at the end of the litigation, and serve the ends of justice, a protective order 8 9 for such information is justified in this matter. It is the intent of the parties that 10 information will not be designated as confidential for tactical reasons and that 11 nothing be so designated without a good faith belief that it has been maintained in 12 13 a confidential, non-public manner, and there is good cause why it should not be 14 part of the public record of this case. 15

C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

16 17 The parties further acknowledge, as set forth in Section 12.3, below, that this 18 Stipulated Protective Order does not entitle them to file confidential information 19 20 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 21 and the standards that will be applied when a party seeks permission from the court 22 to file material under seal. 23 24 There is a strong presumption that the public has a right of access to judicial 25 proceedings and records in civil cases. In connection with non-dispositive motions, 26 good cause must be shown to support a filing under seal. See Kamakana v. City 27 28 and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. 1 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony 2 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective 3 orders require good cause showing), and a specific showing of good cause or 4 5 compelling reasons with proper evidentiary support and legal justification, must be 6 made with respect to Protected Material that a party seeks to file under seal. The 7 parties’ mere designation of Disclosure or Discovery Material as 8 9 CONFIDENTIAL does not—without the submission of competent evidence by 10 declaration, establishing that the material sought to be filed under seal qualifies as 11 confidential, privileged, or otherwise protectable—constitute good cause. 12 13 Further, if a party requests sealing related to a dispositive motion or trial, 14 then compelling reasons, not only good cause, for the sealing must be shown, and 15 the relief sought shall be narrowly tailored to serve the specific interest to be 16 17 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 18 2010). For each item or type of information, document, or thing sought to be filed 19 20 or introduced under seal in connection with a dispositive motion or trial, the party 21 seeking protection must articulate compelling reasons, supported by specific facts 22 and legal justification, for the requested sealing order. Again, competent evidence 23 24 supporting the application to file documents under seal must be provided by 25 declaration. 26 Any document that is not confidential, privileged, or otherwise protectable 27 28 in its entirety will not be filed under seal if the confidential portions can be 1 redacted. If documents can be redacted, then a redacted version for public viewing, 2 omitting only the confidential, privileged, or otherwise protectable portions of the 3 document, shall be filed. Any application that seeks to file documents under seal in 4 5 their entirety should include an explanation of why redaction is not feasible. 6 2. DEFINITIONS 7 2.1 Action: The instant pending action, entitled: Brashear, et al. v. Magnet 8 9 Media, Inc., et al., bearing case no. 2:17-CV-06026-AB-AFM. 10 2.2 Challenging Party: a Party or Non-Party that challenges the designation 11 of information or items under this Order. 12 13 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 14 how it is generated, stored or maintained) or tangible things that qualify for 15 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 16 17 the Good Cause Statement. 18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 19 20 support staff). 21 2.5 Designating Party: a Party or Non-Party that designates information or 22 items that it produces in disclosures or in responses to discovery as 23 24 “CONFIDENTIAL.” 25 2.6 Disclosure or Discovery Material: all items or information, regardless of 26 the medium or manner in which it is generated, stored, or maintained (including, 27 28 among other things, testimony, transcripts, and tangible things), that are produced 1 or 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 4 5 as 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 9 counsel. 10 2.9 Non-Party: any natural person, partnership, corporation, association or 11 other legal entity not named as a Party to this action. 12 13 2.10 Outside Counsel of Record: attorneys who are not employees of a party 14 to this Action but are retained to represent or advise a party to this Action and have 15 appeared in this Action on behalf of that party or are affiliated with a law firm that 16 17 has appeared on behalf of that party, and includes support staff. 18 2.11 Party: any party to this Action, including all of its officers, directors, 19 20 employees, consultants, retained experts, and Outside Counsel of Record (and their 21 support staffs). 22 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 23 24 Discovery Material in this Action. 25 2.13 Professional Vendors: persons or entities that provide litigation support 26 services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 28 demonstrations, and organizing, storing, or retrieving data in any form or medium) 1 and their employees and subcontractors. 2 2.14 Protected Material: any Disclosure or Discovery Material that is 3 designated as “CONFIDENTIAL.” 4 5 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 6 from a Producing Party. 7 3. SCOPE 8 9 The protections conferred by this Stipulation and Order cover not only 10 Protected Material (as defined above), but also (1) any information copied or 11 extracted from Protected Material; (2) all copies, excerpts, summaries, or 12 13 compilations of Protected Material; and (3) any testimony, conversations, or 14 presentations by Parties or their Counsel that might reveal Protected Material. 15 Any use of Protected Material at trial shall be governed by the orders of the 16 17 trial judge. This Order does not govern the use of Protected Material at trial. 18 4. DURATION 19 20 Once a case proceeds to trial, information that was designated as 21 CONFIDENTIAL or maintained pursuant to this protective order used or 22 introduced as an exhibit at trial becomes public and will be presumptively 23 24 available to all members of the public, including the press, unless compelling 25 reasons supported by specific factual findings to proceed otherwise are made to the 26 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 27 28 (distinguishing “good cause” showing for sealing documents produced in 1 discovery from “compelling reasons” standard when merits-related documents are 2 part of court record). Accordingly, the terms of this protective order do not extend 3 beyond the commencement of the trial. 4 5 5. DESIGNATING PROTECTED MATERIAL 6 5.1 Exercise of Restraint and Care in Designating Material for Protection. 7 Each Party or Non-Party that designates information or items for protection under 8 9 this Order must take care to limit any such designation to specific material that 10 qualifies under the appropriate standards. The Designating Party must designate for 11 protection only those parts of material, documents, items, or oral or written 12 13 communications that qualify so that other portions of the material, documents, 14 items, or communications for which protection is not warranted are not swept 15 unjustifiably within the ambit of this Order. 16 17 Mass, indiscriminate, or routinized designations are prohibited. Designations 18 that are shown to be clearly unjustified or that have been made for an improper 19 20 purpose (e.g., to unnecessarily encumber or retard the case development process or 21 to impose unnecessary expenses and burdens on other parties) expose the 22 Designating Party to sanctions. 23 24 If it comes to a Designating Party’s attention that information or items that it 25 designated for protection do not qualify for protection, that Designating Party must 26 promptly notify all other Parties that it is withdrawing the mistaken designation. 27 28 5.2 Manner and Timing of Designations. Except as otherwise provided in 1 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 2 stipulated or ordered, Disclosure or Discovery Material that qualifies for 3 protection under this Order must be clearly so designated before the material is 4 5 disclosed or produced. 6 Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic 8 9 documents, but excluding transcripts of depositions or other pretrial or trial 10 proceedings), that the Producing Party affix at a minimum, the legend 11 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 12 13 contains protected material. If only a portion of the material on a page qualifies for 14 protection, the Producing Party also must clearly identify the protected portion(s) 15 (e.g., by making appropriate markings in the margins). 16 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 20 which material it would like copied and produced. During the inspection and 21 before the designation, all of the material made available for inspection shall be 22 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 23 24 documents it wants copied and produced, the Producing Party must determine 25 which documents, or portions thereof, qualify for protection under this Order. 26 Then, before producing the specified documents, the Producing Party must affix 27 28 the “CONFIDENTIAL legend” to each page that contains Protected Material. If 1 only a portion of the material on a page qualifies for protection, the Producing 2 Party also must clearly identify the protected portion(s) (e.g., by making 3 appropriate markings in the margins). 4 5 (b) for testimony given in depositions that the Designating Party 6 identifies the Disclosure or Discovery Material on the record, before the close of 7 the deposition all protected testimony. 8 9 (c) for information produced in some form other than documentary and 10 for any other tangible items, that the Producing Party affix in a prominent place on 11 the exterior of the container or containers in which the information is stored the 12 13 legend “CONFIDENTIAL.” If only a portion or portions of the information 14 warrants protection, the Producing Party, to the extent practicable, shall identify 15 the protected portion(s). 16 17 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 18 failure to designate qualified information or items does not, standing alone, waive 19 20 the Designating Party’s right to secure protection under this Order for such 21 material. Upon timely correction of a designation, the Receiving Party must make 22 reasonable efforts to assure that the material is treated in accordance with the 23 24 provisions of this Order. 25 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 26 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 27 28 designation of confidentiality at any time that is consistent with the Court’s 1 Scheduling Order. 2 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 3 resolution process under Local Rule 37-1 et seq. 4 5 6.3 Joint Stipulation. Any challenge submitted to the court shall be via 6 joint stipulation pursuant to Local Rule 37-2. 7 6.4 The burden of persuasion in any such challenge proceeding shall be 8 9 on the Designating Party. Frivolous challenges, and those made for an improper 10 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 11 parties) may expose the Challenging Party to sanctions. Unless the Designating 12 13 Party has waived ow withdrawn the confidentiality designation, all parties shall 14 continue to afford the material in question the level of protection to which it is 15 entitled under the Producing Party’s designation until the Court rules on the 16 17 challenge. 18 7. ACCESS TO AND USE OF PROTECTED MATERIAL 19 20 7.1 Basic Principles. A Receiving Party may use Protected Material that is 21 disclosed or produced by another Party or by a Non-Party in connection with this 22 case only for prosecuting, defending, or attempting to settle this litigation. Such 23 24 Protected Material may be disclosed only to the categories of persons and under 25 the conditions described in this Order. When the Action has been terminated, a 26 Receiving Party must comply with the provisions of section 13 below (FINAL 27 28 DISPOSITION). 1 Protected Material must be stored and maintained by a Receiving Party at a 2 location and in a secure manner that ensures that access is limited to the persons 3 authorized under this Order. 4 5 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 6 otherwise ordered by the court or permitted in writing by the Designating Party, a 7 Receiving Party may disclose any information or item designated 8 9 “CONFIDENTIAL” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 11 as employees of said Outside Counsel of Record to whom it is reasonably 12 13 necessary to disclose the information for this Action; 14 (b) the officers, directors, and employees (including House Counsel) of 15 the Receiving Party to whom disclosure is reasonably necessary for this litigation 16 17 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 18

A);

19 20 (c) Experts (as defined in this Order) of the Receiving Party to whom 21 disclosure is reasonably necessary for this litigation and who have signed the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 24 (d) the court and its personnel; 25 (e) court reporters and their staff; 26 (f) professional jury or trial consultants, mock jurors, and Professional 27 28 Vendors to whom disclosure is reasonably necessary for this litigation and who 1 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 2 (g) the author or recipient of a document containing the information or a 3 custodian or other person who otherwise possessed or knew the information; 4 5 (h) during their depositions, witnesses, and attorneys for witnesses, in 6 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 7 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 8 9 they will not be permitted to keep any confidential information unless they sign the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 11 agreed by the Designating Party or ordered by the court. Pages of transcribed 12 13 deposition testimony or exhibits to depositions that reveal Protected Material must 14 be separately bound by the court reporter and may not be disclosed to anyone 15 except as permitted under this Stipulated Protective Order; and 16 17 (i) any mediator or settlement officer, and their supporting personnel, 18 mutually agreed upon by any of the parties engaged in settlement discussions. 19 20 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 21 OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation 23 24 that compels disclosure of any information or items designated in this Action as 25 “CONFIDENTIAL,” that Party must: 26 (a) promptly notify in writing the Designating Party. Such notification 27 28 shall include a copy of the subpoena or court order; 1 (b) promptly notify in writing the party who caused the subpoena or 2 order to issue in the other litigation that some or all of the material covered by the 3 subpoena or order is subject to this Protective Order. Such notification shall 4 5 include a copy of this Stipulated Protective Order; and 6 (c) cooperate with respect to all reasonable procedures sought to be 7 pursued by the Designating Party whose Protected Material may be affected. 8 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 13 subpoena or order issued, unless the Party has obtained the Designating Party’s 14 permission. The Designating Party shall bear the burden and expense of seeking 15 protection in that court of its confidential material and nothing in these provisions 16 17 should be construed as authorizing or encouraging a Receiving Party in this Action 18 to disobey a lawful directive from another court. 19 20 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 21 PRODUCED IN THIS LITIGATION 22 (a) The terms of this Order are applicable to information produced by a 23 24 Non-Party in this action and designated as “CONFIDENTIAL.” Such information 25 produced by Non-Parties in connection with this litigation is protected by the 26 remedies and relief provided by this Order. Nothing in these provisions should be 27 28 construed as prohibiting a Non-Party from seeking additional protections. 1 (b) In the event that a Party is required, by a valid discovery request, to 2 produce a Non-Party’s confidential information in its possession, and the Party is 3 subject to an agreement with the Non-Party not to produce the Non-Party’s 4 5 confidential information, then the Party shall: 6 (1) promptly notify in writing the Requesting Party and the Non-Party 7 that some or all of the information requested is subject to a confidentiality 8 9 agreement with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated 11 Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 13 specific description of the information requested; and 14 (3) make the information requested available for inspection by the 15 Non-Party, if requested. 16 17 (c) If the Non-Party fails to seek a protective order from this court within 18 14 days of receiving the notice and accompanying information, the Receiving 19 20 Party may produce the Non-Party’s confidential information responsive to the 21 discovery request. If the Non-Party timely seeks a protective order, the Receiving 22 Party shall not produce any information in its possession or control that is subject 23 24 to the confidentiality agreement with the Non-Party before a determination by the 25 court. Absent a court order to the contrary, the Non-Party shall bear the burden 26 and expense of seeking protection in this court of its Protected Material. 27 28 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 1 If a Receiving Party learns that, by inadvertence or otherwise, it has 2 disclosed Protected Material to any person or in any circumstance not authorized 3 under this Stipulated Protective Order, the Receiving Party must immediately (a) 4 5 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 6 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 7 the person or persons to whom unauthorized disclosures were made of all the terms 8 9 of this Order, and (d) request such person or persons to execute the 10 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 11 A. 12 13 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 14

PROTECTED MATERIAL

15 When a Producing Party gives notice to Receiving Parties that certain 16 17 inadvertently produced material is subject to a claim of privilege or other 18 protection, the obligations of the Receiving Parties are those set forth in Federal 19 20 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 21 whatever procedure may be established in an e-discovery order that provides for 22 production without prior privilege review. Pursuant to Federal Rule of Evidence 23 24 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 25 of a communication or information covered by the attorney-client privilege or 26 work product protection, the parties may incorporate their agreement in the 27 28 stipulated protective order submitted to the court. 1 12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 3 person to seek its modification by the court in the future. 4 5 12.2 Right to Assert Other Objections. By stipulating to the entry of this 6 Protective Order no Party waives any right it otherwise would have to object to 7 disclosing or producing any information or item on any ground not addressed in 8 9 this Stipulated Protective Order. Similarly, no Party waives any right to object on 10 any ground to use in evidence of any of the material covered by this Protective 11 Order. 12 13 12.3 Filing Protected Material. A Party that seeks to file under seal any 14 Protected Material must comply with Civil Local Rule 79-5. Protected Material 15 may only be filed under seal pursuant to a court order authorizing the sealing of the 16 17 specific Protected Material at issue. If a Party's request to file Protected Material 18 under seal is denied by the court, then the Receiving Party may file the information 19 20 in the public record unless otherwise instructed by the court. 21 13. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in paragraph 4, within 23 24 60 days of a written request by the Designating Party, each Receiving Party must 25 return all Protected Material to the Producing Party or destroy such material. As 26 used in this subdivision, “all Protected Material” includes all copies, abstracts, 27 28 compilations, summaries, and any other format reproducing or capturing any of the 1 Protected Material. Whether the Protected Material is returned or destroyed, the 2 Receiving Party must submit a written certification to the Producing Party (and, if 3 not the same person or entity, to the Designating Party) by the 60 day deadline that 4 5 (1) identifies (by category, where appropriate) all the Protected Material that was 6 returned or destroyed and (2) affirms that the Receiving Party has not retained any 7 copies, abstracts, compilations, summaries or any other format reproducing or 8 9 capturing any of the Protected Material. Notwithstanding this provision, Counsel 10 are entitled to retain an archival copy of all pleadings, motion papers, trial, 11 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 12 13 and trial exhibits, expert reports, attorney work product, and consultant and expert 14 work product, even if such materials contain Protected Material. Any such archival 15 copies that contain or constitute Protected Material remain subject to this 16 17 Protective Order as set forth in Section 4 (DURATION). 18 14. VIOLATION 19 20 Any violation of this Order may be punished by appropriate measures 21 including, without limitation, contempt proceedings and/or monetary sanctions. 22

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

23 24 DATED: _____10/30/2019___________ ______/s Alan Harris_______________________ 25 Attorneys for Plaintiff 26 27 DATED: _____10/30/2019___________ ________/s Phillip G. Ray____________________ Attorneys for Defendant Magnet Media, Inc. 28 1 2 || DATED: ___ 10/30/2019 /s Jeffrey Weston 3 Attorneys for Defendant Complex Media, Inc. 4 5

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

6 7 || DATED: 11/1/2019 8 . 9 10 || ALEXANDER F. MacKINNON 11 United States Magistrate Judge 12

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Zz 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], declare under penalty of perjury that I have read in its entirety and 5 understand the 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 Brashear, et al. v. Magnet Media, Inc., et 7 al.Case No. 2:17-cv-06026-AB-AFM. I agree to comply with and to be bound by all the terms of 8 this Stipulated Protective Order and I understand and acknowledge that failure to so comply could 9 expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will 10 not disclose in any manner any information or item that is subject to this Stipulated Protective 11 Order to any person or entity except in strict compliance with the provisions of this Order. 12 I further agree to submit to the jurisdiction of the United States District Court for the Central 13 District of California for the purpose of enforcing the terms of this Stipulated Protective Order, 14 even if such enforcement proceedings occur after termination of this action. 15 I hereby appoint __________________________ [print or type full name] of 16 _______________________________________ [print or type full address and telephone number] 17 as my California agent for service of process in connection with this action or any proceedings 18 related to enforcement of this Stipulated Protective Order. 19 20 Date: ______________________________________ 21 City and State where sworn and signed: _________________________________ 22 23 Printed name: _______________________________ 24 25 Signature: __________________________________ 26 27 28