1 BROWNE GEORGE ROSS

O’BRIEN ANNAGUEY & ELLIS LLP

2 Peter W. Ross (State Bar No. 109741) pross@bgrfirm.com 3 Eric C. Lauritsen (State Bar No. 301219) elauritsen@bgrfirm.com 4 2121 Avenue of the Stars, Suite 2800 Los Angeles, California 90067 5 Telephone: (310) 274-7100 Facsimile: (310) 275-5697 6 Attorneys for Plaintiff and Counter- 7 Defendant Starship, LLC and Third Party Defendants Frank Mechaly and David 8 Mathey

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

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12 STARSHIP, LLC dba ROCKSTAR Case No. 2:21-CV-04665-JAK (JEMx) 13 ORIGINAL, a California limited District Judge John A. Kronstadt 14 liability company,

15 Plaintiff, STIPULATED PROTECTIVE

ORDER1

16 vs. Trial Date: None Set 17 GHACHAM, INC., a California 18 corporation; GFTD, an unknown business entity; ALI DAOUD 19 GHACHAM, an individual; 20 MOHAMED GHACHAM, an individual; and DOES 1-10, inclusive; 21 Defendants. 22

23 GHACHAM, INC., a California corporation, 24

25 Counter-Claimant, 26 1 This Stipulated Protective Order is based substantially on the model protective 27 order provided under Magistrate Judge Alexander F. MacKinnon’s Procedures. 1 vs. 2

3 STARSHIP, LLC dba ROCKSTAR ORIGINAL, a California limited 4 liability company; FRANK MECHALY, an individual; DAVID 5 MATHEWS, an individual; and DOES 6 1-10, inclusive.

7 Counter-Defendants. 8

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 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 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. 11 B. GOOD CAUSE STATEMENT 12 This action is likely to involve trade secrets, customer and pricing lists and 13 other valuable research, development, commercial, financial, technical and/or 14 proprietary information for which special protection from public disclosure and 15 from use for any purpose other than prosecution of this action is warranted. Such 16 confidential and proprietary materials and information consist of, among other 17 things, confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, development, or 19 commercial information (including information implicating privacy rights of third 20 parties), information otherwise generally unavailable to the public, or which may be 21 privileged or otherwise protected from disclosure under state or federal statutes, 22 court rules, case decisions, or common law. Accordingly, to expedite the flow of 23 information, to facilitate the prompt resolution of disputes over confidentiality of 24 discovery materials, to adequately protect information the parties are entitled to keep 25 confidential, to ensure that the parties are permitted reasonable necessary uses of 26 such material in preparation for and in the conduct of trial, to address their handling 27 at the end of the litigation, and serve the ends of justice, a protective order for such 1 will not be designated as confidential for tactical reasons and that nothing be so 2 designated without a good faith belief that it has been maintained in a confidential, 3 non-public manner, and there is good cause why it should not be part of the public 4 record of this case. 5 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 6 SEAL 7 The parties further acknowledge, as set forth in Section 12.3, below, that this 8 Stipulated Protective Order does not entitle them to file confidential information 9 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 10 and the standards that will be applied when a party seeks permission from the court 11 to file material under seal. 12 There is a strong presumption that the public has a right of access to judicial 13 proceedings and records in civil cases. In connection with non-dispositive motions, 14 good cause must be shown to support a filing under seal. See Kamakana v. City and 15 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 16 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 17 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 18 require good cause showing), and a specific showing of good cause or compelling 19 reasons with proper evidentiary support and legal justification, must be made with 20 respect to Protected Material that a party seeks to file under seal. The parties’ mere 21 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 22 without the submission of competent evidence by declaration, establishing that the 23 material sought to be filed under seal qualifies as confidential, privileged, or 24 otherwise protectable—constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, then 26 compelling reasons, not only good cause, for the sealing must be shown, and the 27 relief sought shall be narrowly tailored to serve the specific interest to be protected. 1 each item or type of information, document, or thing sought to be filed or introduced 2 under seal in connection with a dispositive motion or trial, the party seeking 3 protection must articulate compelling reasons, supported by specific facts and legal 4 justification, for the requested sealing order. Again, competent evidence supporting 5 the application to file documents under seal must be provided by declaration. 6 Any document that is not confidential, privileged, or otherwise protectable in 7 its entirety will not be filed under seal if the confidential portions can be redacted. If 8 documents can be redacted, then a redacted version for public viewing, omitting 9 only the confidential, privileged, or otherwise protectable portions of the document, 10 shall be filed. Any application that seeks to file documents under seal in their 11 entirety should include an explanation of why redaction is not feasible. 12 2. DEFINITIONS 13 2.1 Action: this pending federal lawsuit. 14 2.2 Challenging Party: a Party or Non-Party that challenges the designation 15 of information or items under this Order. 16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 17 how it is generated, stored or maintained) or tangible things that qualify for 18 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 19 the Good Cause Statement. 20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 21 their support staff). 22 2.5 Designating Party: a Party or Non-Party that designates information or 23 items that it produces in disclosures or in responses to discovery as 24 “CONFIDENTIAL.” 25 2.6 Disclosure or Discovery Material: all items or information, regardless 26 of the medium or manner in which it is generated, stored, or maintained (including, 27 among other things, testimony, transcripts, and tangible things), that are produced or 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 that 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, and Outside Counsel of Record (and their 15 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 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 Once a case proceeds to trial, information that was designated as 8 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 9 as an exhibit at trial becomes public and will be presumptively available to all 10 members of the public, including the press, unless compelling reasons supported by 11 specific factual findings to proceed otherwise are made to the trial judge in advance 12 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 13 showing for sealing documents produced in discovery from “compelling reasons” 14 standard when merits-related documents are part of court record). Accordingly, the 15 terms of this protective 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 under 19 this Order must take care to limit any such designation to specific material that 20 qualifies under the appropriate standards. The Designating Party must designate for 21 protection only those parts of material, documents, items or oral or written 22 communications that qualify so that other portions of the material, documents, items 23 or communications for which protection is not warranted are not swept unjustifiably 24 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 1 Party to sanctions. 2 If it comes to a Designating Party’s attention that information or items that it 3 designated for protection do not qualify for protection, that Designating Party must 4 promptly notify all other Parties that it is withdrawing the inapplicable designation. 5 5.2 Manner and Timing of Designations. Except as otherwise provided in 6 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 7 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 8 under this Order must be clearly so designated before the material is disclosed or 9 produced. 10 Designation in conformity with this Order requires: 11 (a) for information in documentary form (e.g., paper or electronic 12 documents, but excluding transcripts of depositions or other pretrial or trial 13 proceedings), that the Producing Party affix at a minimum, the legend 14 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 15 contains protected material. If only a portion of the material on a page qualifies for 16 protection, the Producing Party also must clearly identify the protected portion(s) 17 (e.g., by making appropriate markings in the margins). 18 A Party or Non-Party that makes original documents available for inspection 19 need not designate them for protection until after the inspecting Party has indicated 20 which documents 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 documents it wants copied and produced, the Producing Party must determine which 24 documents, or portions thereof, qualify for protection under this Order. Then, before 25 producing the specified documents, the Producing Party must affix the 26 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 27 portion of the material on a page qualifies for protection, the Producing Party also 1 in the margins). 2 (b) for testimony given in depositions that the Designating Party identifies the 3 Disclosure or Discovery Material on the record, before the close of the deposition all 4 protected testimony. 5 (c) for information produced in some form other than documentary and for 6 any other tangible items, that the Producing Party affix in a prominent place on the 7 exterior of the container or containers in which the information is stored the legend 8 “CONFIDENTIAL.” If only a portion or portions of the information warrants 9 protection, the Producing Party, to the extent practicable, shall identify the protected 10 portion(s). 11 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 12 failure to designate qualified information or items does not, standing alone, waive 13 the Designating Party’s right to secure protection under this Order for such material. 14 Upon timely correction of a designation, the Receiving Party must make reasonable 15 efforts to assure that the material is treated in accordance with the provisions of this 16 Order. 17 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 18 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 19 designation of confidentiality at any time that is consistent with the Court’s 20 Scheduling Order. 21 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 22 resolution process under Local Rule 37-1 et seq. 23 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 24 joint stipulation pursuant to Local Rule 37-2. 25 6.4 The burden of persuasion in any such challenge proceeding shall be on the 26 Designating Party. Frivolous challenges, and those made for an improper purpose 27 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 1 or withdrawn the confidentiality designation, all parties shall continue to afford the 2 material in question the level of protection to which it is entitled under the 3 Producing Party’s designation until the Court rules on the challenge. 4 7. ACCESS TO AND USE OF PROTECTED MATERIAL 5 7.1 Basic Principles. A Receiving Party may use Protected Material that is 6 disclosed or produced by another Party or by a Non-Party in connection with this 7 Action only for prosecuting, defending or attempting to settle this Action. Such 8 Protected Material may be disclosed only to the categories of persons and under the 9 conditions described in this Order. When the Action has been terminated, a 10 Receiving Party must comply with the provisions of section 13 below (FINAL 11 DISPOSITION). 12 Protected Material must be stored and maintained by a Receiving Party at a 13 location and in a secure manner that ensures that access is limited to the persons 14 authorized under this Order. 15 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 16 otherwise ordered by the court or permitted in writing by the Designating Party, a 17 Receiving Party may disclose any information or item designated 18 “CONFIDENTIAL” only to: 19 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 20 employees of said Outside Counsel of Record to whom it is reasonably necessary to 21 disclose the information for this Action; 22 (b) the officers, directors, and employees (including House Counsel) of the 23 Receiving Party to whom disclosure is reasonably necessary for this Action; 24 (c) Experts (as defined in this Order) of the Receiving Party to whom 25 disclosure is reasonably necessary for this Action and who have signed the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) the court and its personnel; 1 (f) professional jury or trial consultants, mock jurors, and Professional 2 Vendors to whom disclosure is reasonably necessary for this Action and who have 3 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) the author or recipient of a document containing the information or a 5 custodian or other person who otherwise possessed or knew the information; 6 (h) during their depositions, witnesses, and attorneys for witnesses, in the 7 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 8 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 9 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 deposition testimony or exhibits to depositions that reveal Protected Material may 13 be separately bound by the court reporter and may not be disclosed to anyone except 14 as permitted under this Stipulated Protective Order; 15 (i) any mediator or settlement officer, and their supporting personnel, 16 mutually agreed upon by any of the parties engaged in settlement discussions; and 17 (j) appropriate representatives of the Receiving Party’s insurance carrier. 18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 19 IN OTHER LITIGATION 20 If a Party is served with a subpoena or a court order issued in other litigation 21 that compels disclosure of any information or items designated in this Action as 22 “CONFIDENTIAL,” that Party must: 23 (a) promptly notify in writing the Designating Party. Such notification shall 24 include a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or order to 26 issue in the other litigation that some or all of the material covered by the subpoena 27 or order is subject to this Protective Order. Such notification shall include a copy of 1 (c) cooperate with respect to all reasonable procedures sought to be pursued 2 by the Designating Party whose Protected Material may be affected. 3 If the Designating Party timely seeks a protective order, the Party served with 4 the subpoena or court order shall not produce any information designated in this 5 action as “CONFIDENTIAL” before a determination by the court from which the 6 subpoena or order issued, unless the Party has obtained the Designating Party’s 7 permission. The Designating Party shall bear the burden and expense of seeking 8 protection in that court of its confidential material and nothing in these provisions 9 should be construed as authorizing or encouraging a Receiving Party in this Action 10 to disobey a lawful directive from another court. 11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 12 PRODUCED IN THIS LITIGATION 13 (a) The terms of this Order are applicable to information produced by a Non- 14 Party in this Action and designated as “CONFIDENTIAL.” Such information 15 produced by Non-Parties in connection with this litigation is protected by the 16 remedies and relief provided by this Order. Nothing in these provisions should be 17 construed as prohibiting a Non-Party from seeking additional protections. 18 (b) In the event that a Party is required, by a valid discovery request, to 19 produce a Non-Party’s confidential information in its possession, and the Party is 20 subject to an agreement with the Non-Party not to produce the Non-Party’s 21 confidential information, then the Party shall: 22 (1) promptly notify in writing the Requesting Party and the Non-Party that 23 some or all of the information requested is subject to a confidentiality agreement 24 with a Non-Party; 25 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 26 Order in this Action, the relevant discovery request(s), and a reasonably specific 27 description of the information requested; and 1 if requested. 2 (c) If the Non-Party fails to seek a protective order from this court within 14 3 days of receiving the notice and accompanying information, the Receiving Party 4 may produce the Non-Party’s confidential information responsive to the discovery 5 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 6 not produce any information in its possession or control that is subject to the 7 confidentiality agreement with the Non-Party before a determination by the court. 8 Absent a court order to the contrary, the Non-Party shall bear the burden and 9 expense of seeking protection in this court of its Protected Material. 10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 12 Protected Material to any person or in any circumstance not authorized under this 13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 14 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 15 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 16 persons to whom unauthorized disclosures were made of all the terms of this Order, 17 and (d) request such person or persons to execute the “Acknowledgment and 18 Agreement to Be Bound” that is attached hereto as Exhibit A. 19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20 PROTECTED MATERIAL 21 When a Producing Party gives notice to Receiving Parties that certain 22 inadvertently produced material is subject to a claim of privilege or other protection, 23 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 24 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 25 may be established in an e-discovery order that provides for production without 26 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 27 as the parties reach an agreement on the effect of disclosure of a communication or 1 parties may incorporate their agreement in the stipulated protective order submitted 2 to the court. 3 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 5 person to seek its modification by the Court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry of this 7 Protective Order, no Party waives any right it otherwise would have to object to 8 disclosing or producing any information or item on any ground not addressed in this 9 Stipulated Protective Order. Similarly, no Party waives any right to object on any 10 ground to use in evidence of any of the material covered by this Protective Order. 11 12.3 Filing Protected Material. A Party that seeks to file under seal any 12 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 13 only be filed under seal pursuant to a court order authorizing the sealing of the 14 specific Protected Material at issue. If a Party’s request to file Protected Material 15 under seal is denied by the court, then the Receiving Party may file the information 16 in the public record unless otherwise instructed by the court. 17 13. FINAL DISPOSITION 18 After the final disposition of this Action, as defined in paragraph 4, within 60 19 days of a written request by the Designating Party, each Receiving Party must return 20 all Protected Material to the Producing Party or destroy such material. As used in 21 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 22 summaries, and any other format reproducing or capturing any of the Protected 23 Material. Whether the Protected Material is returned or destroyed, the Receiving 24 Party must submit a written certification to the Producing Party (and, if not the same 25 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 26 (by category, where appropriate) all the Protected Material that was returned or 27 destroyed and (2) affirms that the Receiving Party has not retained any copies, 1 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 2 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 3 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 4 reports, attorney work product, and consultant and expert work product, even if such 5 materials contain Protected Material. Any such archival copies that contain or 6 constitute Protected Material remain subject to this Protective Order as set forth in 7 Section 4 (DURATION). 8 14. VIOLATION 9 Any violation of this Order may be punished by appropriate measures 10 including, without limitation, contempt proceedings and/or monetary sanctions. 11 12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 13 DATED: November 2, 2021 BROWNE GEORGE ROSS

O’BRIEN ANNAGUEY & ELLIS LLP

14 Peter W. Ross 15 Eric C. Lauritsen

16

17 By: /s/ Peter W. Ross Peter W. Ross 18 Attorneys for Plaintiff and Counter-Defendant 19 Starship, LLC and Third Party Defendants Frank Mechaly and David Mathey 20

21 DATED: November 2, 2021 MURPHY, PEARSON, BRADLEY & 22 FEENEY Keith G. Adams 23 Joshua Y. Quaye 24 25 By: /s/ Keith G. Adams 26 Keith G. Adams 27 Attorneys for Defendants Ghacham, Inc, Ali Daoud Ghacham, and Mohamed Ghacham 1 DATED: November 2, 2021 ARMINAK LAW, APC Tamar G. Arminak 2 Nelly Ispiryan 3 Mary S. Boyadjian 4 5 By: /s/ Tamar G. Arminak Tamar G. Arminak 6 Attorneys for Counter-Claimant Ghacham, Inc. 7 Pursuant to Local Rule 5-4.3.4(a)(2)(i), I, Eric Lauritsen, attest that all other 8 signatories listed, and on whose behalf this filing is submitted, concur in the filing’s 9 content and have authorized the filing. 10 /s Eric Lauritsen 11 Eric Lauritsen 12

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

13 14 15 Dated: _1_1_/_3_/_2_0_2_1______________ 16 ______________________________ 17

JOHN E. MCDERMOTT

18 United States Magistrate Judge 19 20 21 22 23 24 25 26 27 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 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on _________________ [date] in the case of Starship, LLC dba Rockstar Original v. 8 Ghacham, Inc. et al., Case No. 2:21-CV-04665-JAK (JEMx). I agree to comply with 9 and to be bound by all the terms of this Stipulated Protective Order and I understand 10 and acknowledge that failure to so comply could expose me to sanctions and 11 punishment in the nature of contempt. I solemnly promise that I will not disclose in 12 any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this 14 Order. I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of 17 this action. I hereby appoint __________________________ [print or type full 18 name] of _______________________________________ [print or type full address 19 and telephone number] as my California agent for service of process in connection 20 with this action or any proceedings related to enforcement of this Stipulated 21 Protective Order. 22 Date: ______________________________________ City and State where sworn and signed: _________________________________ 23 Printed name: _______________________________ 24 Signature: __________________________________ 25 26 27