1 DAVID R. ZARO (BAR NO. 124334)

JOSHUA A. DEL CASTILLO (BAR NO. 239015)

2 NORMAN M. ASPIS (BAR NO. 313466)

ALLEN MATKINS LECK GAMBLE

3 MALLORY & NATSIS LLP 865 South Figueroa Street, Suite 2800 4 Los Angeles, California 90017-2543 Phone: (213) 622-5555 5 Fax: (213) 620-8816 E-Mail: dzaro@allenmatkins.com 6 jdelcastillo@allenmatkins.com naspis@allenmatkins.com 7 Attorneys for Plaintiff 8 GEOFF WINKLER, RECEIVER

9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 GEOFF WINKLER, RECEIVER, Case No. 2:21-cv-00869-FMO-AFM

13 Plaintiff, STIPULATED PROTECTIVE ORDER

14 v.

15 915 ELM AVENUE CVL, LLC

16 Defendant.

17 18 STIPULATED PROTECTIVE ORDER 19 The following Stipulated Protective Order1 ("Order") is entered into by and 20 between Plaintiff Geoff Winkler ("Plaintiff" or the "Receiver"), the Court-appointed 21 permanent receiver for Essex Capital Corporation and its subsidiaries and affiliates 22 in the matter styled SEC v. Iannelli, et al., USDC, C.D. Cal. Case No. 2:18-cv- 23 05008-FMO-AFM, on the one hand, and Defendant 915 Elm Avenue CVL, LLC 24 ("Defendant" or "CVL") on the other hand, and with respect to the following 25 matters: 26 27

28 1 This Stipulated Protective Order is based substantially on the model protective 1 I. A. PURPOSES AND LIMITATIONS 2 Discovery in this Action is likely to involve production of confidential or 3 private financial information for which special protection from public disclosure and 4 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 Order. The Receiver and CVL acknowledge that this Order does not 7 confer blanket protections on all disclosures or responses to discovery, and that the 8 protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under applicable legal 10 principles. 11 B. GOOD CAUSE STATEMENT 12 This Action is likely to involve private information of a financial and/or 13 accounting nature for which special protection from public disclosure and from use 14 for any purpose other than prosecution of this Action is warranted. The Parties 15 contend that certain materials produced in the course of discovery may implicate 16 their rights and the rights of non-parties, including the privacy right in the materials 17 and, additionally, such private materials and information may consist of, among 18 other things, confidential business, financial, or accounting information, information 19 regarding confidential business practices, information otherwise generally 20 unavailable to the public, or which may be privileged or otherwise protected from 21 disclosure under state or federal statutes, court rules, case decisions, or common 22 law. Accordingly, to expedite the flow of information, to facilitate the prompt 23 resolution of disputes over confidentiality of discovery materials, to adequately 24 protect information the Parties are entitled to keep confidential, to ensure that the 25 Parties are permitted reasonable necessary uses of such material in preparation for 26 and in the conduct of trial, to address their handling at the end of the litigation, and 27 serve the ends of justice, a protective order for such information is justified in this 28 matter. It is the intent of the Parties that information will not be designated as 1 confidential for tactical reasons, and that nothing be so designated without a good 2 faith belief that it has been maintained in a confidential, non-public manner, and 3 there is good cause why it should not be part of the public record of this Action. 4 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 5 SEAL 6 The Parties further acknowledge, as set forth in Section 12.3, below, that this 7 Order does not entitle them to file confidential information under seal; Local Civil 8 Rule 79-5 sets forth the procedures that must be followed and the standards that will 9 be applied when a Party seeks permission from the Court to file material under seal. 10 There is a strong presumption that the public has a right of access to judicial 11 proceedings and records in civil cases. In connection with non-dispositive motions, 12 good cause must be shown to support a filing under seal. See Kamakana v. City and 13 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 14 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 15 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 16 require good cause showing), and a specific showing of good cause or compelling 17 reasons with proper evidentiary support and legal justification, must be made with 18 respect to Protected Material that a party seeks to file under seal. The Parties' mere 19 designation of Disclosure or Discovery Material as "CONFIDENTIAL" does not – 20 without the submission of competent evidence by declaration, establishing that the 21 material sought to be filed under seal qualifies as confidential, privileged, or 22 otherwise protectable – constitute good cause. 23 Further, if a Party requests sealing related to a dispositive motion or trial, then 24 compelling reasons, not only good cause, for the sealing must be shown, and the 25 relief sought shall be narrowly tailored to serve the specific interest to be protected. 26 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For 27 each item or type of information, document, or thing sought to be filed or introduced 28 under seal in connection with a dispositive motion or trial, the Party seeking 1 protection must articulate compelling reasons, supported by specific facts and legal 2 justification, for the requested sealing order. Again, competent evidence supporting 3 the application to file documents under seal must be provided by declaration. 4 Any document that is not confidential, privileged, or otherwise protectable in 5 its entirety will not be filed under seal if the confidential portions can be redacted. 6 If documents can be redacted, then a redacted version for public viewing, omitting 7 only the confidential, privileged, or otherwise protectable portions of the document, 8 shall be filed. Any application that seeks to file documents under seal in their 9 entirety should include an explanation of why redaction is not feasible. 10 2. DEFINITIONS 11 Action: the action styled Winkler v. 915 Elm Avenue CVL, LLC, Case No. 12 2:21-cv-00869-FMO-AFM, currently pending before this Court; 13 Challenging Party: a Party or Non-Party that challenges the designation of 14 information or items under this Order; 15 "CONFIDENTIAL" Information or Items: information (regardless of how it 16 is generated, stored or maintained) or tangible things that qualify for protection 17 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 18 Cause Statement; 19 Counsel: Outside Counsel of Record and House Counsel (as well as their 20 support staff); 21 Designating Party: a Party or Non-Party that designates information or items 22 that it produces in disclosures or in responses to discovery as "CONFIDENTIAL"; 23 Disclosure or Discovery Material: all items or information, regardless of the 24 medium or manner in which it is generated, stored, or maintained (including, among 25 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 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 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 Non-Party: any natural person, partnership, corporation, association or other 8 legal entity not named as a Party to this Action; 9 Outside Counsel of Record: attorneys who are not employees of a Party to 10 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 that 12 has appeared on behalf of that Party, and includes support staff; 13 Party: any party to this Action, including the Receiver and CVL, all of their 14 respective officers, directors, employees, consultants, retained experts, and Outside 15 Counsel of Record (and their support staffs); 16 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 17 Material in this Action; 18 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 Protected Material: any Disclosure or Discovery Material that is designated 23 as "CONFIDENTIAL"; and 24 Receiving Party: a Party that receives Disclosure or Discovery Material from 25 a Producing Party. 26 3. SCOPE 27 The protections conferred by this Order cover not only Protected Material (as 28 defined above), but also (1) any information copied or extracted from Protected 1 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 2 and (3) any testimony, conversations, or presentations by Parties or their Counsel 3 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 Once a case proceeds to trial, information that was designated as 8 "CONFIDENTIAL", or maintained pursuant to this Order, used or introduced as an 9 exhibit at trial becomes public and will be presumptively available to all members of 10 the public, including the press, unless compelling reasons supported by specific 11 factual findings to proceed otherwise are made to the trial judge in advance of the 12 trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing "good cause" showing for 13 sealing documents produced in discovery from "compelling reasons" standard when 14 merits-related documents are part of court record). Accordingly, the terms of this 15 Order do not extend beyond the commencement of the trial. 16 5. DESIGNATING PROTECTED MATERIAL 17 5.1 Exercise of Restraint and Care in Designating Material for Protection. 18 Each Party or Non-Party that designates information or items for protection 19 under this Order must take care to limit any such designation to specific material 20 that qualifies under the appropriate standards. The Designating Party must 21 designate for protection only those parts of material, documents, items or oral or 22 written communications that qualify so that other portions of the material, 23 documents, items or communications for which protection is not warranted are not 24 swept unjustifiably within the ambit of this Order. 25 Mass, indiscriminate or routinized designations are prohibited. Designations 26 that are shown to be clearly unjustified or that have been made for an improper 27 purpose (e.g., to unnecessarily encumber the case development process or to impose 28 1 unnecessary expenses and burdens on other parties) may expose the Designating 2 Party to sanctions. 3 If it comes to a Designating Party's attention that information or items that it 4 designated for protection do not qualify for protection, that Designating Party must 5 promptly notify all other Parties that it is withdrawing the inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided in 7 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 8 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 9 under this Order must be clearly so designated before the material is disclosed or 10 produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions or other pretrial or trial 14 proceedings), that the Producing Party affix at a minimum, the legend 15 "CONFIDENTIAL" (hereinafter "CONFIDENTIAL legend"), to each page that 16 contains protected material. If only a portion of the material on a page qualifies for 17 protection, the Producing Party also must clearly identify the protected portion(s) 18 (e.g., by making appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and 22 before the designation, all of the material made available for inspection shall be 23 deemed "CONFIDENTIAL". After the inspecting Party has identified the 24 documents it wants copied and produced, the Producing Party must determine which 25 documents, or portions thereof, qualify for protection under this Order. Then, 26 before producing the specified documents, the Producing Party must affix the 27 CONFIDENTIAL legend to each page that contains Protected Material. If only a 28 portion of the material on a page qualifies for protection, the Producing Party also 1 must clearly identify the protected portion(s) (e.g., by making appropriate markings 2 in the margins). 3 (b) for testimony given in depositions that the Designating Party 4 identifies the Disclosure or Discovery Material on the record, before the close of the 5 deposition all protected testimony. 6 (c) for information produced in some form other than documentary 7 and for any other tangible items, that the Producing Party affix in a prominent place 8 on the exterior of the container or containers in which the information is stored the 9 legend "CONFIDENTIAL". If only a portion or portions of the information 10 warrants protection, the Producing Party, to the extent practicable, shall identify the 11 protected portion(s). 12 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 13 failure to designate qualified information or items does not, standing alone, waive 14 the Designating Party’s right to secure protection under this Order for such material. 15 Upon timely correction of a designation, the Receiving Party must make reasonable 16 efforts to assure that the material is treated in accordance with the provisions of this 17 Order. 18 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 19 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 20 designation of confidentiality at any time that is consistent with the Court's 21 Scheduling Order. 22 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 23 resolution process under Local Rule 37-1, et seq. 24 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 25 joint stipulation pursuant to Local Rule 37-2. 26 6.4 The burden of persuasion in any such challenge proceeding shall be on 27 the Designating Party. Frivolous challenges, and those made for an improper 28 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 1 parties) may expose the Challenging Party to sanctions. Unless the Designating 2 Party has waived or withdrawn the confidentiality designation, all parties shall 3 continue to afford the material in question the level of protection to which it is 4 entitled under the Producing Party's designation until the Court rules on the 5 challenge. 6 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7 7.1 Basic Principles. A Receiving Party may use Protected Material that is 8 disclosed or produced by another Party or by a Non-Party in connection with this 9 Action only for prosecuting, defending or attempting to settle this Action. Such 10 Protected Material may be disclosed only to the categories of persons and under the 11 conditions described in this Order. When this Action has been terminated, a 12 Receiving Party must comply with the provisions of section 13 below. 13 Protected Material must be stored and maintained by a Receiving Party at a 14 location and in a secure manner that ensures that access is limited to the persons 15 authorized under this Order. 16 7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless 17 otherwise ordered by the court or permitted in writing by the Designating Party, a 18 Receiving Party may disclose any information or item designated 19 "CONFIDENTIAL" only to: 20 (a) the Receiving Party's Outside Counsel of Record in this Action, 21 as well as employees of said Outside Counsel of Record to whom it is reasonably 22 necessary to disclose the information for this Action; 23 (b) the officers, directors, and employees (including House Counsel) 24 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 25 (c) Experts (as defined in this Order) of the Receiving Party to 26 whom disclosure is reasonably necessary for this Action and who have signed the 27 "Acknowledgment and Agreement to Be Bound" (Exhibit A); 28 (d) the Court and its personnel; 1 (e) Court reporters and their staff; 2 (f) professional jury or trial consultants, mock jurors, and 3 Professional Vendors to whom disclosure is reasonably necessary for this Action 4 and who have signed the "Acknowledgment and Agreement to Be Bound" 5 (Exhibit A); 6 (g) the author or recipient of a document containing the information 7 or a custodian or other person who otherwise possessed or knew the information; 8 (h) during their depositions, witnesses, and attorneys for witnesses, 9 in the Action to whom disclosure is reasonably necessary provided: (1) the 10 deposing party requests that the witness sign the form attached as Exhibit 1 hereto; 11 and (2) they will not be permitted to keep any confidential information unless they 12 sign the "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless 13 otherwise agreed by the Designating Party or ordered by the Court. Pages of 14 transcribed deposition testimony or exhibits to depositions that reveal Protected 15 Material may be separately bound by the court reporter and may not be disclosed to 16 anyone except as permitted under this Order; and 17 (i) any mediator or settlement officer, and their supporting 18 personnel, mutually agreed upon by any of the parties engaged in settlement 19 discussions. 20 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 21 PRODUCED IN OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation 23 that compels disclosure of any information or items designated in this Action as 24 "CONFIDENTIAL", that Party must: 25 (a) promptly notify in writing the Designating Party. Such 26 notification shall include a copy of the subpoena or court order; 27 (b) promptly notify in writing the party who caused the subpoena or 28 order to issue in the other litigation that some or all of the material covered by the 1 subpoena or order is subject to this Order. Such notification shall include a copy of 2 this Order; and 3 (c) cooperate with respect to all reasonable procedures sought to be 4 pursued by the Designating Party whose Protected Material may be affected. 5 If the Designating Party timely seeks a protective order, the Party served with 6 the subpoena or court order shall not produce any information designated in this 7 Action as "CONFIDENTIAL" before a determination by the court from which the 8 subpoena or order issued, unless the Party has obtained the Designating Party's 9 permission. The Designating Party shall bear the burden and expense of seeking 10 protection in that court of its confidential material and nothing in these provisions 11 should be construed as authorizing or encouraging a Receiving Party in this Action 12 to disobey a lawful directive from another court. 13 9. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 14 PRODUCED IN THIS LITIGATION 15 (a) The terms of this Order are applicable to information produced 16 by a Non-Party in this Action and designated as "CONFIDENTIAL". Such 17 information produced by Non-Parties in connection with this litigation is protected 18 by the remedies and relief provided by this Order. Nothing in these provisions 19 should be construed as prohibiting a Non-Party from seeking additional protections. 20 (b) In the event that a Party is required, by a valid discovery request, 21 to produce a Non-Party's confidential information in its possession, and the Party is 22 subject to an agreement with the Non-Party not to produce the Non-Party's 23 confidential information, then the Party shall: 24 (1) promptly notify in writing the Requesting Party and the 25 Non-Party that some or all of the information requested is subject to a 26 confidentiality agreement with a Non-Party; 27 28 1 (2) promptly provide the Non-Party with a copy of this Order, 2 the relevant discovery request(s), and a reasonably specific description of the 3 information requested; and 4 (3) make the information requested available for inspection by 5 the Non-Party, if requested. 6 (c) If the Non-Party fails to seek a protective order from this court 7 within 14 days of receiving the notice and accompanying information, the Receiving 8 Party may produce the Non-Party's confidential information responsive to the 9 discovery request. If the Non-Party timely seeks a protective order, the Receiving 10 Party shall not produce any information in its possession or control that is subject to 11 the confidentiality agreement with the Non-Party before a determination by the 12 court. Absent a court order to the contrary, the Non-Party shall bear the burden and 13 expense of seeking protection in this court of its Protected Material. 14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 16 Protected Material to any person or in any circumstance not authorized under this 17 Order, the Receiving Party must immediately (a) notify in writing the Designating 18 Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 19 unauthorized copies of the Protected Material, (c) inform the person or persons to 20 whom unauthorized disclosures were made of all the terms of this Order, and 21 (d) request such person or persons to execute the "Acknowledgment and Agreement 22 to Be Bound" that is attached hereto as Exhibit A. 23 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 24 PROTECTED MATERIAL 25 When a Producing Party gives notice to Receiving Parties that certain 26 inadvertently produced material is subject to a claim of privilege or other protection, 27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 28 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 1 procedure may be established in an e-discovery order that provides for production 2 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 3 (e), insofar as the Parties reach an agreement on the effect of disclosure of a 4 communication or information covered by the attorney-client privilege or work 5 product protection, the Parties may incorporate their agreement in the stipulated 6 protective order submitted to the Court. 7 12. MISCELLANEOUS 8 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 9 person to seek its modification by the Court in the future. 10 12.2 Right to Assert Other Objections. By stipulating to the entry of this 11 Order, no Party waives any right it otherwise would have to object to disclosing or 12 producing any information or item on any ground not addressed in this Order. 13 Similarly, no Party waives any right to object on any ground to use in evidence of 14 any of the material covered by this Order. 15 12.3 Filing Protected Material. A Party that seeks to file under seal any 16 Protected Material must comply with Local Civil Rule 79-5. Protected Material 17 may only be filed under seal pursuant to a court order authorizing the sealing of the 18 specific Protected Material at issue. If a Party's request to file Protected Material 19 under seal is denied by the court, then the Receiving Party may file the information 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 60 23 days after a written request by the Designating Party, each Receiving Party must 24 return all Protected Material to the Producing Party or destroy such material. As 25 used in this subdivision, "all Protected Material" includes all copies, abstracts, 26 compilations, summaries, and any other format reproducing or capturing any of the 27 Protected Material. Whether the Protected Material is returned or destroyed, the 28 Receiving Party must submit a written certification to the Producing Party (and, if 1 | not the same person or entity, to the Designating Party) by the 60-day deadline that 2 | (1) identifies (by category, where appropriate) all the Protected Material that was 3 | returned or destroyed and (2) affirms that the Receiving Party has not retained any 4 | copies, abstracts, compilations, summaries or any other format reproducing or 5 | capturing any of the Protected Material. Notwithstanding this provision, Counsel 6 | are entitled to retain an archival copy of all pleadings, motion papers, trial, 7 | deposition, and hearing transcripts, legal memoranda, correspondence, deposition 8 | and trial exhibits, expert reports, attorney work product, and consultant and expert 9 | work product, even if such materials contain Protected Material. Any such archival 10 | copies that contain or constitute Protected Material remain subject to this Order as 11 | set forth in Section 4. 12}14. VIOLATION 13 Any violation of this Order may be punished by appropriate measures 14 | including, without limitation, contempt proceedings and/or monetary sanctions. 15 16 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 17 18 | Dated: August 23, 2021 ALLEN MATKINS LECK GAMBLE

MALLORY & NATSIS LLP

19 DAVID R. ZARO

JOSHUA A. DEL CASTILLO

20 NORMAN M. ASPIS 21 By: 22 23 vat GALE 24 JOSHUA A. DEL CASTILLO Attorneys for Court-Appointed 25 Receiver

GEOFF WINKLER

26 27 28 Leck Gamble QTTIDITT ATRT) PROTERCTIVE ORINER

2 | Dated: August 23, 2021 CAPELLO & NOEL LLP 3 DAVID L. COUSINEAU

4 By: /s/__ David L. Cousineau 5 Ritorneys for Defendant. ‘ 915 ELM AVENUE CVL, LLC 8 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 91DATED: 8/23/2021 10 11 12 (dy Mir. f<_—~ 13 14 HON. ALEXANDER F. MacKINNON United States Magistrate Judge

16 17 18 19 20 21 22 23 24 25 26 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ______________________________ [print or type full name], of 4 ______________________________ [print or type full address], declare under 5 penalty of perjury that I have read in its entirety and understand the Stipulated 6 Protective Order that was issued by the United States District Court for the Central 7 District of California on [date] in the case of Winkler v. 915 Elm Avenue CVL, 8 LLC, Case No. 2:21-cv-00869-FMO-AFM. I agree to comply with and to be bound 9 by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Order. I 14 further agree to submit to the jurisdiction of the United States District Court for the 15 Central District of California for enforcing the terms of this Stipulated Protective 16 Order, even if such enforcement proceedings occur after termination of this action. 17 I hereby appoint ____________________ [print or type full name] of 18 ______________________________ [print or type full address and telephone 19 number] as my California agent for service of process in connection with this action 20 or any proceedings related to enforcement of this Stipulated Protective Order. 21 22 Date: ______________________________ 23 City and State where sworn and signed: ______________________________ 24 25 Printed name: ______________________________ 26 27 Signature: ______________________________ 28