GS Holistic, LLC v. One Stop Vape

• Court: District Court, C.D. California
• Decided: May 22, 2025
• Docket: 2:24-cv-08060
• Status: Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA 3

4 GS HOLISTIC, LLC, Case No.: 2:24-cv-08060 CV 5 Plaintiff(s), (SSCx)

6 v. [DISCOVERY MATTER]

7 ONE STOP VAPE, et al. STIPULATED PROTECTIVE 8 ORDER1

9 Defendant(s).

12 1. INTRODUCTION 13 1.1 Purposes and Limitations. Discovery in this action is likely to 14 involve production of confidential, proprietary, or private information for 15 which special protection from public disclosure and from use for any 16 17 purpose other than prosecuting this litigation may be warranted. 18 Accordingly, the parties hereby stipulate to and petition the court to enter 19 the following Stipulated Protective Order. The parties acknowledge that 20 this Order does not confer blanket protections on all disclosures or 21 responses to discovery and that the protection it affords from public 22 disclosure and use extends only to the limited information or items that 23 are entitled to confidential treatment under the applicable legal 24 principles. 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Stephanie S. 1 1.2 Good Cause Statement. 2 This action is likely to involve trade secrets, and other valuable 3 development, commercial, financial, technical and/or proprietary 4 information for which special protection from public disclosure and from 5 use for any purpose other than prosecution of this action is warranted. The 6 Plaintiff contends that disclosure of trade secrets, technical and/or 7 proprietary information, including design specifications, and counterfeit 8 identification criteria, will result in significant and irreparable harm such 9 as a loss of ability to enforce intellectual property rights and irreparable 10 harm to good and brand reputation as a result thereof. Such confidential 11 and proprietary materials and information consist of, among other things, 12 business or financial information, information regarding product 13 development and manufacturing, counterfeit identification guides, or 14 other commercial information (including information implicating privacy 15 rights of third parties), information otherwise generally unavailable to the 16 public, or which may be privileged or otherwise protected from disclosure 17 under state or federal statutes, court rules, case decisions, or common law. 18 Accordingly, to expedite the flow of information, to facilitate the prompt 19 resolution of disputes over confidentiality of discovery materials, to 20 adequately protect information the parties are entitled to keep 21 22 confidential, to ensure that the parties are permitted reasonable necessary 23 uses of such material in preparation for and in the conduct of trial, to 24 address their handling at the end of the litigation, and serve the ends of 25 justice, a protective order for such information is justified in this matter. 26 It is the intent of the parties that information will not be designated as 27 confidential for tactical reasons and that nothing be so designated without 1 manner, and there is good cause why it should not be part of the public 2 record of this case. 3 1.3 Acknowledgment of Procedure for Filing Under Seal. The 4 parties further acknowledge, as set forth in Section 12.3, below, that this 5 Stipulated Protective Order does not entitle them to file confidential 6 information under seal; Local Rule 79-5 sets forth the procedures that 7 must be followed and the standards that will be applied when a party 8 seeks permission from the court to file material under seal. 9 There is a strong presumption that the public has a right of access 10 to judicial proceedings and records in civil cases. In connection with non- 11 dispositive motions, good cause must be shown to support a filing under 12 seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176 13 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307 14 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony Elecs., Inc., 15 187 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 17 compelling reasons with proper evidentiary support and legal 18 justification, must be made with respect to Protected Material that a 19 party seeks to file under seal. The parties’ mere designation of Disclosure 20 or Discovery Material as CONFIDENTIAL does not—without the 21 22 submission of competent evidence by declaration, establishing that the 23 material sought to be filed under seal qualifies as confidential, privileged, 24 or otherwise protectable—constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion 26 or trial, then compelling reasons, not only good cause, for the sealing must 27 be shown, and the relief sought shall be narrowly tailored to serve the 1 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of information, 2 document, or thing sought to be filed or introduced under seal in 3 connection with a dispositive motion or trial, the party seeking protection 4 must articulate compelling reasons, supported by specific facts and legal 5 justification, for the requested sealing order. Again, competent evidence 6 supporting the application to file documents under seal must be provided 7 by declaration. 8 Any document that is not confidential, privileged, or otherwise 9 protectable in its entirety will not be filed under seal if the confidential 10 portions can be redacted. If documents can be redacted, then a redacted 11 version for public viewing, omitting only the confidential, privileged, or 12 otherwise protectable portions of the document, shall be filed. Any 13 application that seeks to file documents under seal in their entirety 14 should include an explanation of why redaction is not feasible. 15

16 2. DEFINITIONS 17 18 2.1 Action: this pending federal lawsuit. 19 2.2 Challenging Party: a Party or Non-Party that challenges the 20 designation of information or items under this Order. 21 2.3 “CONFIDENTIAL” Information or Items: information 22 (regardless of how it is generated, stored or maintained) or tangible 23 things that qualify for protection under Rule 26(c) of the Federal Rules of 24 Civil Procedure, and as specified above in the Good Cause Statement. 25 2.4 Counsel: Outside Counsel of Record and House Counsel (as 26 well as their support staff). 27 2.5 Designating Party: a Party or Non-Party that designates 1 information or items that it produces in disclosures or in responses to 2 discovery as “CONFIDENTIAL.” 3 2.6 Disclosure or Discovery Material: all items or information, 4 regardless of the medium or manner in which it is generated, stored, or 5 maintained (including, among other things, testimony, transcripts, and 6 tangible things), that are produced or generated in disclosures or 7 responses to discovery in this matter. 8 2.7 Expert: a person with specialized knowledge or experience in a 9 matter pertinent to the litigation who has been retained by a Party or its 10 counsel to serve as an expert witness or as a consultant in this Action. 11 2.8 Final Disposition: the later of (1) dismissal of all claims and 12 defenses in this Action, with or without prejudice; and (2) final judgment 13 herein after the completion and exhaustion of all appeals, rehearings, 14 remands, trials, or reviews of this Action, including the time limits for 15 filing any motions or applications for extension of time pursuant to 16 applicable law. 17 2.9 In-House Counsel: attorneys who are employees of a party to 18 this Action. In-House Counsel does not include Outside Counsel of Record 19 or any other outside counsel. 20 2.10 Non-Party: any natural person, partnership, corporation, 21 22 association, or other legal entity not named as a Party to this action. 23 2.11 Outside Counsel of Record: attorneys who are not employees of 24 a party to this Action but are retained to represent or advise a party to 25 this Action and have appeared in this Action on behalf of that party or are 26 affiliated with a law firm which has appeared on behalf of that party, and 27 includes support staff. 1 directors, employees, consultants, retained experts, and Outside Counsel 2 of Record (and their support staffs). 3 2.13 Producing Party: a Party or Non-Party that produces 4 Disclosure or Discovery Material in this Action. 5 2.14 Professional Vendors: persons or entities that provide 6 litigation- support services (e.g., photocopying, videotaping, translating, 7 preparing exhibits or demonstrations, and organizing, storing, or 8 retrieving data in any form or medium) and their employees and 9 subcontractors. 10 2.15 Protected Material: any Disclosure or Discovery Material that 11 is designated as “CONFIDENTIAL” 12 2.16 Receiving Party: a Party that receives Disclosure or Discovery 13 Material from a Producing Party. 14

15 3. SCOPE 16 The protections conferred by this Stipulation and Order cover not 17 18 only Protected Material (as defined above), but also (1) any information 19 copied or extracted from Protected Material; (2) all copies, excerpts, 20 summaries, or compilations of Protected Material; and (3) any testimony, 21 conversations, or presentations by Parties or their Counsel that might 22 reveal Protected Material. 23 Any use of Protected Material at trial shall be governed by the 24 orders of the trial judge. This Stipulated Protective Order does not 25 govern the use of Protected Material at trial. 26 27 1 4. TRIAL AND DURATION 2 The terms of this Stipulated Protective Order apply through Final 3 Disposition of the Action. 4 Once a case proceeds to trial, information that was designated as 5 CONFIDENTIAL or maintained pursuant to this Stipulated Protective 6 Order and used or introduced as an exhibit at trial becomes public and 7 will be presumptively available to all members of the public, including 8 the press, unless compelling reasons supported by specific factual 9 findings to proceed otherwise are made to the trial judge in advance of 10 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 11 cause” showing for sealing documents produced in discovery from 12 “compelling reasons” standard when merits-related documents are part 13 14 of court record). Accordingly, for such materials, the terms of this 15 Stipulated Protective Order do not extend beyond the commencement of 16 the trial. 17 Even after Final Disposition of this litigation, the confidentiality 18 obligations imposed by this Stipulated Protective Order shall remain in 19 effect until a Designating Party agrees otherwise in writing or a court 20 order otherwise directs. 21 22 5. DESIGNATING PROTECTED MATERIAL 23 5.1 Exercise of Restraint and Care in Designating Material for 24 Protection. Each Party or Non-Party that designates information or items 25 for protection under this Order must take care to limit any such 26 designation to specific material that qualifies under the appropriate 27 1 those parts of material, documents, items, or oral or written 2 communications that qualify so that other portions of the material, 3 documents, items, or communications for which protection is not 4 warranted are not swept unjustifiably within the ambit of this Order. 5 Mass, indiscriminate, or routinized designations are prohibited. 6 Designations that are shown to be clearly unjustified or that have been 7 made for an improper purpose (e.g., to unnecessarily encumber the case 8 development process or to impose unnecessary expenses and burdens on 9 other parties) may expose the Designating Party to sanctions. 10 If it comes to a Designating Party’s attention that information or 11 items that it designated for protection do not qualify for protection, that 12 Designating Party must promptly notify all other Parties that it is 13 withdrawing the inapplicable designation. 14 5.2 Manner and Timing of Designations. Except as otherwise 15 provided in this Stipulated Protective Order (see, e.g., second paragraph of 16 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 17 18 Discovery Material that qualifies for protection under this Stipulated 19 Protective Order must be clearly so designated before the material is 20 disclosed or produced. 21 Designation in conformity with this Stipulated Protective Order 22 requires: 23 (a) for information in documentary form (e.g., paper or electronic 24 documents, but excluding transcripts of depositions or other pretrial or 25 trial proceedings), that the Producing Party affix at a minimum, the 26 legend “CONFIDENTIAL” to each page that contains protected material. 27 If only a portion or portions of the material on a page qualifies for 1 protection, the Producing Party also must clearly identify the protected 2 portion(s) (e.g., by making appropriate markings in the margins). 3 A Party or Non-Party that makes original documents available for 4 inspection need not designate them for protection until after the 5 inspecting Party has indicated which documents it would like copied and 6 produced. During the inspection and before the designation, all of the 7 material made available for inspection shall be deemed 8 CONFIDENTIAL. After the inspecting Party has identified the 9 documents it wants copied and produced, the Producing Party must 10 determine which documents, or portions thereof, qualify for protection 11 under this Stipulated Protective Order. Then, before producing the 12 specified documents, the Producing Party must affix the 13 “CONFIDENTIAL” legend to each page that contains Protected Material. 14 If only a portion or portions of the material on a page qualifies for 15 protection, the Producing Party also must clearly identify the protected 16 portion(s) (e.g., by making appropriate markings in the margins). 17 (b) for testimony given in depositions that the Designating Party 18 identify the Disclosure or Discovery Material on the record, before the 19 close of the deposition all protected testimony. 20 (c) for information produced in some form other than 21 22 documentary and for any other tangible items, that the Producing Party 23 affix in a prominent place on the exterior of the container or containers in 24 which the information is stored the “CONFIDENTIAL” legend. If only a 25 portion or portions of the information warrants protection, the Producing 26 Party, to the extent practicable, shall identify the protected portion(s). 27 5.3 Inadvertent Failures to Designate. If timely corrected, an 1 inadvertent failure to designate qualified information or items does not, 2 standing alone, waive the Designating Party’s right to secure protection 3 under this Order for such material. Upon timely correction of a 4 designation, the Receiving Party must make reasonable efforts to assure 5 that the material is treated in accordance with the provisions of this 6 Stipulated Protective Order. 7 8 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 9 6.1 Timing of Challenges. Any Party or Non-Party may challenge 10 a designation of confidentiality at any time that is consistent with the 11 court’s Scheduling Order. 12 6.2 Meet and Confer. The Challenging Party shall initiate the 13 dispute resolution process under Local Rule 37.1 et seq. and with Section 14 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-Discovery 15 Motion Conference.”2 16 6.3 The burden of persuasion in any such challenge proceeding 17 18 shall be on the Designating Party. Frivolous challenges, and those made 19 for an improper purpose (e.g., to harass or impose unnecessary expenses 20 and burdens on other parties) may expose the Challenging Party to 21 sanctions. Unless the Designating Party has waived or withdrawn the 22 confidentiality designation, all parties shall continue to afford the 23 material in question the level of protection to which it is entitled under 24 the Producing Party’s designation until the court rules on the challenge. 25 26

27 2 Judge Christensen’s Procedures are available at 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected 3 Material that is disclosed or produced by another Party or by a Non-Party 4 in connection with this Action only for prosecuting, defending, or 5 attempting to settle this Action. Such Protected Material may be 6 disclosed only to the categories of persons and under the conditions 7 described in this Order. When the Action reaches a Final Disposition, a 8 Receiving Party must comply with the provisions of section 13 below. 9 Protected Material must be stored and maintained by a Receiving 10 Party at a location and in a secure manner that ensures that access is 11 limited to the persons authorized under this Stipulated Protective Order. 12 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 13 Unless otherwise ordered by the court or permitted in writing by the 14 Designating Party, a Receiving Party may disclose any information or 15 item designated “CONFIDENTIAL” only: 16 (a) to the Receiving Party’s Outside Counsel of Record in this 17 18 Action, as well as employees of said Outside Counsel of Record to whom 19 it is reasonably necessary to disclose the information for this Action; 20 (b) to the officers, directors, and employees (including House 21 Counsel) of the Receiving Party to whom disclosure is reasonably 22 necessary for this Action; 23 (c) to Experts (as defined in this Order) of the Receiving Party to 24 whom disclosure is reasonably necessary for this Action and who have 25 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 (d) to the court and its personnel; 27 (e) to court reporters and their staff; 1 (f) to professional jury or trial consultants, mock jurors, and 2 Professional Vendors to whom disclosure is reasonably necessary for this 3 Action and who have signed the “Acknowledgment and Agreement to Be 4 Bound” (Exhibit A); 5 (g) to the author or recipient of a document containing the 6 information or a custodian or other person who otherwise possessed or 7 knew the information; 8 (h) during their depositions, to witnesses, and attorneys for 9 witnesses, in the Action to whom disclosure is reasonably necessary, 10 provided: (1) the deposing party requests that the witness sign the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the 12 witness will not be permitted to keep any confidential information unless 13 they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 14 unless otherwise agreed by the Designating Party or ordered by the court. 15 Pages of transcribed deposition testimony or exhibits to depositions that 16 reveal Protected Material may be separately bound by the court reporter 17 and may not be disclosed to anyone except as permitted under this 18 Stipulated Protective Order; and 19 (i) to any mediator or settlement officer, and their supporting 20 personnel, mutually agreed upon by any of the parties engaged in 21 22 settlement discussions. 23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 24 PRODUCED IN OTHER LITIGATION 25 26 If a Party is served with a subpoena or a court order issued in other 27 litigation that compels disclosure of any information or items designated 1 (a) promptly notify in writing the Designating Party. Such 2 notification shall include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena 4 or order to issue in the other litigation that some or all of the material 5 covered by the subpoena or order is subject to this Protective Order. Such 6 notification shall include a copy of this Stipulated Protective Order; and 7 (c) cooperate with respect to all reasonable procedures sought to 8 be pursued by the Designating Party whose Protected Material may be 9 affected. 10 If the Designating Party timely seeks a protective order, the 11 Party served with the subpoena or court order shall not produce any 12 information designated in this action as “CONFIDENTIAL” before a 13 determination by the court from which the subpoena or order issued, 14 unless the Party has obtained the Designating Party’s permission. The 15 Designating Party shall bear the burden and expense of seeking 16 protection in that court of its confidential material and nothing in these 17 provisions should be construed as authorizing or encouraging a Receiving 18 Party in this Action to disobey a lawful directive from another court. 19

20 21 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 22 PRODUCED IN THIS LITIGATION 23 9.1 Application. The terms of this Stipulated Protective Order are 24 applicable to information produced by a Non-Party in this Action and 25 designated as “CONFIDENTIAL.” Such information produced by Non- 26 Parties in connection with this litigation is protected by the remedies and 27 relief provided by this Order. Nothing in these provisions should be 1 9.2 Notification. In the event that a Party is required, by a valid 2 discovery request, to produce a Non-Party’s confidential information in its 3 possession, and the Party is subject to an agreement with the Non-Party 4 not to produce the Non-Party’s confidential information, then the Party 5 shall: 6 (a) promptly notify in writing the Requesting Party and the Non- 7 Party that some or all of the information requested is subject to a 8 confidentiality agreement with a Non-Party; 9 (b) make the information requested available for inspection by 10 the Non-Party, if requested. 11 9.3 Conditions of Production. If the Non-Party fails to seek a 12 protective order from this court within 14 days of receiving the notice and 13 accompanying information, the Receiving Party may produce the Non- 14 Party’s confidential information responsive to the discovery request. If the 15 Non-Party timely seeks a protective order, the Receiving Party shall not 16 produce any information in its possession or control that is subject to the 17 confidentiality agreement with the Non-Party before a determination by 18 the court. Absent a court order to the contrary, the Non-Party shall bear 19 the burden and expense of seeking protection in this court of its Protected 20 Material. 21 22 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 24 MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it 26 has disclosed Protected Material to any person or in any circumstance not 27 authorized under this Stipulated Protective Order, the Receiving Party 1 must immediately (a) notify in writing the Designating Party of the 2 unauthorized disclosures, (b) use its best efforts to retrieve all 3 unauthorized copies of the Protected Material, (c) inform the person or 4 persons to whom unauthorized disclosures were made of all the terms of 5 this Order, and (d) request such person or persons to execute the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 7 8 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 9 OTHERWISE PROTECTED MATERIAL 10 When a Producing Party gives notice to Receiving Parties that 11 certain inadvertently produced material is subject to a claim of privilege 12 or other protection, the obligations of the Receiving Parties are those set 13 14 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This 15 provision is not intended to modify whatever procedure may be 16 established in an e-discovery order that provides for production without 17 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal 18 Rules of Evidence, insofar as the parties reach an agreement on the effect 19 of disclosure of a communication or information covered by the attorney- 20 client privilege or work product protection, the parties may incorporate 21 their agreement in the stipulated protective order submitted to the court. 22

23 12. MISCELLANEOUS 24 12.1 Right to Further Relief. Nothing in this Stipulated Protective 25 Order abridges the right of any person to seek its modification by the 26 court in the future. 27 1 of this Stipulated Protective Order no Party waives any right it otherwise 2 would have to object to disclosing or producing any information or item 3 on any ground not addressed in this Stipulated Protective Order. 4 Similarly, no Party waives any right to object on any ground to use in 5 evidence of any of the material covered by this Stipulated Protective 6 Order. 7 12.3 Filing Protected Material. A Party that seeks to file under 8 seal any Protected Material must comply with Local Rule 79-5. Protected 9 Material may only be filed under seal pursuant to a court order 10 authorizing the sealing of the specific Protected Material at issue. If a 11 Party's request to file Protected Material under seal is denied by the 12 court, then the Receiving Party may file the information in the public 13 record unless otherwise instructed by the court. 14

15 13. FINAL DISPOSITION 16 After the Final Disposition of this Action, as defined in paragraph 17 18 4, within 60 days of a written request by the Designating Party, each 19 Receiving Party must return all Protected Material to the Producing 20 Party or destroy such material. As used in this subdivision, “all Protected 21 Material” includes all copies, abstracts, compilations, summaries, and 22 any other format reproducing or capturing any of the Protected Material. 23 Whether the Protected Material is returned or destroyed, the Receiving 24 Party must submit a written certification to the Producing Party (and, if 25 not the same person or entity, to the Designating Party) by the 60 day 26 deadline that (1) identifies (by category, where appropriate) all the 27 Protected Material that was returned or destroyed and (2) affirms that 1 the Receiving Party has not retained any copies, abstracts, compilations, 2 summaries or any other format reproducing or capturing any of the 3 Protected Material. Notwithstanding this provision, Counsel is entitled 4 to retain an archival copy of all pleadings, motion papers, trial, 5 deposition, and hearing transcripts, legal memoranda, correspondence, 6 deposition and trial exhibits, expert reports, attorney work product, and 7 consultant and expert work product, even if such materials contain 8 Protected Material. Any such archival copies that contain or constitute 9 Protected Material remain subject to this Protective Order as set forth in 10 Section 4. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1 || 14. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished 3 || by any and all appropriate measures including, without limitation, 4 || contempt proceedings and/or monetary sanctions. 5 6 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 | DATED: May 20, 2025 __/s/ David L. Perry II 9 David L. Perry II, Esquire 10 Tomas Carlos Leon, Esquire Attorneys for Plaintiff 1] 12 3 DATED: May 20, 2025 /s/ Marcus F. Chaney 14 Marcus F. Chaney Attorney(s) for Defendant(s) 15 16 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. || DATED: May 22, 2025 “0 STEPHANIE 8S. CHRISTENSEN 21 United States Magistrate Judge 22 23 24 25 26 27 28

1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

3 I, ________________________________ [print or type full name], 4 of ________________________________________________________ [print 5 or type full address], declare under penalty of perjury that I have read 6 in its entirety and understand the Stipulated Protective Order that was 7 issued by the United States District Court for the Central District of 8 California on May ___, 2025 in the case of GS Holistic, LLC v. One Stop 9 Vape, Case No.: 2:24-cv-08060 CV (SSCx). I agree to comply with and 10 to be bound by all the terms of this Stipulated Protective Order and I 11 understand and acknowledge that failure to so comply could expose me 12 to sanctions and punishment in the nature of contempt. I solemnly 13 14 promise that I will not disclose in any manner any information or item 15 that is subject to this Stipulated Protective Order to any person or entity 16 except in strict compliance with the provisions of this Order. 17 I further agree to submit to the jurisdiction of the United States 18 District Court for the Central District of California for the purpose of 19 enforcing the terms of this Stipulated Protective Order, even if such 20 enforcement proceedings occur after termination of this action. I hereby 21 appoint ___________________________________________________ 22 [print or type full name] of 23 __________________________________________________________________ 24 [print or type full address and telephone number] as 25 26 27 1 my California agent for service of process in connection with this action 2 or any proceedings related to enforcement of this Stipulated Protective 3 Order. 4 5 Date: ___________________________ 6 City and State where sworn and 7 signed: ___________________________ 8 Printed name: ___________________________ 9 Signature: ___________________________ 10

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27