Jeremy Lewi v. Comenity Capital Bank

• Court: District Court, C.D. California
• Decided: July 14, 2025
• Docket: 2:25-cv-02118
• Status: Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA 3

4 JEREMY LEWI, Case No. 2:25-cv-02118-AB-SSC 5 Plaintiff(s), 6 STIPULATED PROTECTIVE 7 v. ORDER1

8 COMENITY CAPITAL BANK, 9 10 Defendants.

12 13 1. INTRODUCTION 14 1.1 Purposes and Limitations. Discovery in this action is likely to 15 involve production of confidential, proprietary, or private information for 16 which special protection from public disclosure and from use for any 17 purpose other than prosecuting this litigation may be warranted. 18 Accordingly, the parties hereby stipulate to and petition the court to 19 enter the following Stipulated Protective Order. The parties 20 21 acknowledge that this Order does not confer blanket protections on all 22 disclosures or responses to discovery and that the protection it affords 23 from public disclosure and use extends only to the limited information or 24 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Stephanie S. 1 items that are entitled to confidential treatment under the applicable 2 legal principles. 3 1.2 Good Cause Statement. 4 This action is likely to involve trade secrets, consumer information 5 and other valuable research, development, commercial, financial, 6 technical and/or proprietary information for which special protection 7 from public disclosure and from use for any purpose other than 8 prosecution of this action is warranted. Such confidential and 9 proprietary materials and information consist of, among other things, 10 confidential business or financial information, information regarding 11 confidential business practices, or other confidential research, 12 development, or commercial information (including information 13 implicating privacy rights of third parties), information otherwise 14 generally unavailable to the public, or which may be privileged or 15 otherwise protected from disclosure under state or federal statutes, court 16 rules, case decisions, or common law. Accordingly, to expedite the flow of 17 information, to facilitate the prompt resolution of disputes over 18 confidentiality of discovery materials, to adequately protect information 19 the parties are entitled to keep confidential, to ensure that the parties 20 are permitted reasonable necessary uses of such material in preparation 21 22 for and in the conduct of trial, to address their handling at the end of the 23 litigation, and serve the ends of justice, a protective order for such 24 information is justified in this matter. It is the intent of the parties that 25 information will not be designated as confidential for tactical reasons 26 and that nothing be so designated without a good faith belief that it has 27 been maintained in a confidential, non-public manner, and there is good 1 1.3 Acknowledgment of Procedure for Filing Under Seal. The 2 parties further acknowledge, as set forth in Section 12.3, below, that this 3 Stipulated Protective Order does not entitle them to file confidential 4 information under seal; Local Rule 79-5 sets forth the procedures that 5 must be followed and the standards that will be applied when a party 6 seeks permission from the court to file material under seal. 7 There is a strong presumption that the public has a right of access 8 to judicial proceedings and records in civil cases. In connection with 9 non-dispositive motions, good cause must be shown to support a filing 10 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 11 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors 12 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 13 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 14 protective orders require good cause showing), and a specific showing of 15 good cause or compelling reasons with proper evidentiary support and 16 legal justification, must be made with respect to Protected Material that 17 a party seeks to file under seal. The parties’ mere designation of 18 Disclosure or Discovery Material as CONFIDENTIAL does not— 19 without the submission of competent evidence by declaration, 20 establishing that the material sought to be filed under seal qualifies as 21 22 confidential, privileged, or otherwise protectable—constitute good cause. 23 Further, if a party requests sealing related to a dispositive motion 24 or trial, then compelling reasons, not only good cause, for the sealing 25 must be shown, and the relief sought shall be narrowly tailored to serve 26 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 27 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of 1 seal in connection with a dispositive motion or trial, the party seeking 2 protection must articulate compelling reasons, supported by specific 3 facts and legal justification, for the requested sealing order. Again, 4 competent evidence supporting the application to file documents under 5 seal must be provided by declaration. 6 Any document that is not confidential, privileged, or otherwise 7 protectable in its entirety will not be filed under seal if the confidential 8 portions can be redacted. If documents can be redacted, then a redacted 9 version for public viewing, omitting only the confidential, privileged, or 10 otherwise protectable portions of the document, shall be filed. Any 11 application that seeks to file documents under seal in their entirety 12 should include an explanation of why redaction is not feasible. 13

14 2. DEFINITIONS 15 2.1 Action: The above-captioned matter styled as Jeremy Lewi v. 16 Comenity Capital Bank, U.S District Court for the Central District of 17 18 California, Case No. 2:25-cv-02118-AB-SSC. 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 9 a matter pertinent to the litigation who has been retained by a Party or 10 its 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 19 Record 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 24 of 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 26 are affiliated with a law firm which has appeared on behalf of that party, 27 and 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 21 testimony, conversations, or presentations by Parties or their Counsel 22 that might 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 18 Even after Final Disposition of this litigation, the confidentiality 19 obligations imposed by this Stipulated Protective Order shall remain in 20 effect until a Designating Party agrees otherwise in writing or a court 21 order otherwise directs. 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 25 items 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 16 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure 17 18 or 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 27 material. If only a portion or portions of the material on a page 1 qualifies for protection, the Producing Party also must clearly identify 2 the protected portion(s) (e.g., by making appropriate markings in the 3 margins). 4 A Party or Non-Party that makes original documents available for 5 inspection need not designate them for protection until after the 6 inspecting Party has indicated which documents it would like copied 7 and produced. During the inspection and before the designation, all of 8 the material made available for inspection shall be deemed 9 CONFIDENTIAL. After the inspecting Party has identified the 10 documents it wants copied and produced, the Producing Party must 11 determine which documents, or portions thereof, qualify for protection 12 under this Stipulated Protective Order. Then, before producing the 13 specified documents, the Producing Party must affix the 14 “CONFIDENTIAL” legend to each page that contains Protected 15 Material. If only a portion or portions of the material on a page 16 qualifies for protection, the Producing Party also must clearly identify 17 the protected portion(s) (e.g., by making appropriate markings in the 18 margins). 19 (b) for testimony given in depositions that the Designating Party 20 identify the Disclosure or Discovery Material on the record, before the 21 22 close of the deposition all protected testimony. 23 (c) for information produced in some form other than 24 documentary and for any other tangible items, that the Producing Party 25 affix in a prominent place on the exterior of the container or containers 26 in which the information is stored the “CONFIDENTIAL” legend. If only 27 a portion or portions of the information warrants protection, the 1 portion(s). 2 5.3 Inadvertent Failures to Designate. If timely corrected, an 3 inadvertent failure to designate qualified information or items does not, 4 standing alone, waive the Designating Party’s right to secure protection 5 under this Order for such material. Upon timely correction of a 6 designation, the Receiving Party must make reasonable efforts to assure 7 that the material is treated in accordance with the provisions of this 8 Stipulated Protective Order. 9

10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 6.1 Timing of Challenges. Any Party or Non-Party may 12 challenge a designation of confidentiality at any time that is consistent 13 14 with the court’s Scheduling Order. 15 6.2 Meet and Confer. The Challenging Party shall initiate the 16 dispute resolution process under Local Rule 37.1 et seq. and with 17 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre- 18 Discovery Motion Conference.”2 19 6.3 The burden of persuasion in any such challenge proceeding 20 shall be on the Designating Party. Frivolous challenges, and those 21 made for an improper purpose (e.g., to harass or impose unnecessary 22 expenses and burdens on other parties) may expose the Challenging 23 Party to sanctions. Unless the Designating Party has waived or 24 withdrawn the confidentiality designation, all parties shall continue to 25 afford the material in question the level of protection to which it is 26

27 2 Judge Christensen’s Procedures are available at 1 entitled under the Producing Party’s designation until the court rules on 2 the challenge. 3 4 7. ACCESS TO AND USE OF PROTECTED MATERIAL 5 7.1 Basic Principles. A Receiving Party may use Protected 6 Material that is disclosed or produced by another Party or by a Non- 7 Party in connection with this Action only for prosecuting, defending, or 8 attempting to settle this Action. Such Protected Material may be 9 disclosed only to the categories of persons and under the conditions 10 described in this Order. When the Action reaches a Final Disposition, a 11 Receiving Party must comply with the provisions of section 13 below. 12 Protected Material must be stored and maintained by a Receiving 13 Party at a location and in a secure manner that ensures that access is 14 limited to the persons authorized under this Stipulated Protective 15 Order. 16 17 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 18 Unless otherwise ordered by the court or permitted in writing by the 19 Designating Party, a Receiving Party may disclose any information or 20 item designated “CONFIDENTIAL” only: 21 (a) to the Receiving Party’s Outside Counsel of Record in this 22 Action, as well as employees of said Outside Counsel of Record to whom 23 it is reasonably necessary to disclose the information for this Action; 24 (b) to the officers, directors, and employees (including House 25 Counsel) of the Receiving Party to whom disclosure is reasonably 26 necessary for this Action; 27 (c) to Experts (as defined in this Order) of the Receiving Party to 1 whom disclosure is reasonably necessary for this Action and who have 2 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 (d) to the court and its personnel; 4 (e) to court reporters and their staff; 5 (f) to professional jury or trial consultants, mock jurors, and 6 Professional Vendors to whom disclosure is reasonably necessary for 7 this Action and who have signed the “Acknowledgment and Agreement 8 to Be Bound” (Exhibit A); 9 (g) to the author or recipient of a document containing the 10 information or a custodian or other person who otherwise possessed or 11 knew the information; 12 (h) during their depositions, to witnesses, and attorneys for 13 witnesses, in the Action to whom disclosure is reasonably necessary, 14 provided: (1) the deposing party requests that the witness sign the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the 16 witness will not be permitted to keep any confidential information 17 unless they sign the “Acknowledgment and Agreement to Be Bound” 18 (Exhibit A), unless otherwise agreed by the Designating Party or 19 ordered by the court. Pages of transcribed deposition testimony or 20 exhibits to depositions that reveal Protected Material may be separately 21 22 bound by the court reporter and may not be disclosed to anyone except 23 as permitted under this Stipulated Protective Order; and 24 (i) to any mediator or settlement officer, and their supporting 25 personnel, mutually agreed upon by any of the parties engaged in 26 settlement discussions. 27 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2 PRODUCED IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in 4 other litigation that compels disclosure of any information or items 5 designated in this Action as “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such 7 notification shall include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the 9 subpoena or order to issue in the other litigation that some or all of the 10 material covered by the subpoena or order is subject to this Protective 11 Order. Such notification shall include a copy of this Stipulated 12 Protective Order; and 13 14 (c) cooperate with respect to all reasonable procedures sought to 15 be pursued by the Designating Party whose Protected Material may be 16 affected. 17 If the Designating Party timely seeks a protective order, the 18 Party served with the subpoena or court order shall not produce any 19 information designated in this action as “CONFIDENTIAL” before a 20 determination by the court from which the subpoena or order issued, 21 unless the Party has obtained the Designating Party’s permission. The 22 Designating Party shall bear the burden and expense of seeking 23 protection in that court of its confidential material and nothing in these 24 provisions should be construed as authorizing or encouraging a 25 Receiving Party in this Action to disobey a lawful directive from another 26 court. 27 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 9.1 Application. The terms of this Stipulated Protective Order 4 are applicable to information produced by a Non-Party in this Action and 5 designated as “CONFIDENTIAL.” Such information produced by Non- 6 Parties in connection with this litigation is protected by the remedies 7 and relief provided by this Order. Nothing in these provisions should be 8 construed as prohibiting a Non-Party from seeking additional 9 protections. 10 9.2 Notification. In the event that a Party is required, by a valid 11 discovery request, to produce a Non-Party’s confidential information in 12 its possession, and the Party is subject to an agreement with the Non- 13 Party not to produce the Non-Party’s confidential information, then the 14 Party shall: 15 (a) promptly notify in writing the Requesting Party and the 16 Non-Party that some or all of the information requested is subject to a 17 confidentiality agreement with a Non-Party; 18 (b) make the information requested available for inspection by 19 the Non-Party, if requested. 20 9.3 Conditions of Production. If the Non-Party fails to seek a 21 22 protective order from this court within 14 days of receiving the notice 23 and accompanying information, the Receiving Party may produce the 24 Non-Party’s confidential information responsive to the discovery request. 25 If the Non-Party timely seeks a protective order, the Receiving Party 26 shall not produce any information in its possession or control that is 27 subject to the confidentiality agreement with the Non-Party before a 1 Non-Party shall bear the burden and expense of seeking protection in 2 this court of its Protected Material. 3 4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 5 MATERIAL 6 If a Receiving Party learns that, by inadvertence or otherwise, it 7 has disclosed Protected Material to any person or in any circumstance 8 not authorized under this Stipulated Protective Order, the Receiving 9 Party must immediately (a) notify in writing the Designating Party of 10 the unauthorized disclosures, (b) use its best efforts to retrieve all 11 unauthorized copies of the Protected Material, (c) inform the person or 12 persons to whom unauthorized disclosures were made of all the terms of 13 this Order, and (d) request such person or persons to execute the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 15

16 17 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 18 OTHERWISE PROTECTED MATERIAL 19 When a Producing Party gives notice to Receiving Parties that 20 certain inadvertently produced material is subject to a claim of privilege 21 or other protection, the obligations of the Receiving Parties are those set 22 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This 23 provision is not intended to modify whatever procedure may be 24 established in an e-discovery order that provides for production without 25 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal 26 Rules of Evidence, insofar as the parties reach an agreement on the 27 1 attorney-client privilege or work product protection, the parties may 2 incorporate their agreement in the stipulated protective order 3 submitted to the court. 4 5 12. MISCELLANEOUS 6 12.1 Right to Further Relief. Nothing in this Stipulated 7 Protective Order abridges the right of any person to seek its 8 modification by the court in the future. 9 12.2 Right to Assert Other Objections. By stipulating to the entry 10 of this Stipulated Protective Order no Party waives any right it 11 otherwise would have to object to disclosing or producing any 12 information or item on any ground not addressed in this Stipulated 13 Protective Order. Similarly, no Party waives any right to object on any 14 ground to use in evidence of any of the material covered by this 15 Stipulated Protective Order. 16 17 12.3 Filing Protected Material. A Party that seeks to file under 18 seal any Protected Material must comply with Local Rule 79-5. 19 Protected Material may only be filed under seal pursuant to a court 20 order authorizing the sealing of the specific Protected Material at issue. 21 If a Party's request to file Protected Material under seal is denied by the 22 court, then the Receiving Party may file the information in the public 23 record unless otherwise instructed by the court. 24 13. FINAL DISPOSITION 25 After the Final Disposition of this Action, as defined in paragraph 26 4, within 60 days of a written request by the Designating Party, each 27 Receiving Party must return all Protected Material to the Producing 1 Party or destroy such material. As used in this subdivision, “all 2 Protected Material” includes all copies, abstracts, compilations, 3 summaries, and any other format reproducing or capturing any of the 4 Protected Material. Whether the Protected Material is returned or 5 destroyed, the Receiving Party must submit a written certification to 6 the Producing Party (and, if not the same person or entity, to the 7 Designating Party) by the 60 day deadline that (1) identifies (by 8 category, where appropriate) all the Protected Material that was 9 returned or destroyed and (2) affirms that the Receiving Party has not 10 retained any copies, abstracts, compilations, summaries or any other 11 format reproducing or capturing any of the Protected Material. 12 Notwithstanding this provision, Counsel is entitled to retain an archival 13 copy of all pleadings, motion papers, trial, deposition, and hearing 14 transcripts, legal memoranda, correspondence, deposition and trial 15 exhibits, expert reports, attorney work product, and consultant and 16 expert work product, even if such materials contain Protected Material. 17 Any such archival copies that contain or constitute Protected Material 18 remain subject to this Protective Order as set forth in Section 4. 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 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 8 || DATED: July 9, 2025 /s/ Michelle F. Catapang ? Tomio B. Narita 10 Nathan A. Searles Wl Michelle F. Catapang Attorneys for Defendant 12 13 || DATED: July 9, 2025 /s/ Nicholas J. Enns 14 Matthew M. Loker 15 Nicholas J. Enns 6 Attorneys for Plaintiff 17 18 FOR GOOD CAUSE SHOWN, IT IS SO ORDEBED. 19 20 DATED: July 14, 2025 21 STEPHANIE 8. CHRISTENSEN 22 United States Magistrate Judge 23 24 25 26 27 28

1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

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 6 Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the 8 case of Jeremy Lewi v. Comenity Capital Bank, U.S District Court for 9 the Central District of California, Case No. 2:25-cv-02118-AB-SSC . I 10 agree to comply with and to be bound by all the terms of this 11 Stipulated Protective Order and I understand and acknowledge that 12 failure to so comply could expose me to sanctions and punishment in 13 14 the nature of contempt. I solemnly promise that I will not disclose in 15 any manner any information or item that is subject to this Stipulated 16 Protective Order to any person or entity except in strict compliance 17 with the provisions of this Order. 18 I further agree to submit to the jurisdiction of the United States 19 District Court for the Central District of California for the purpose of 20 enforcing the terms of this Stipulated Protective Order, even if such 21 enforcement proceedings occur after termination of this action. I 22 hereby appoint ________________________ [print or type full name] 23 of _________ [print or type full address and telephone number] as 24 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

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