Rosalva Quirarte v. CIOX Health, LLC dba Datavant Group

• Court: District Court, E.D. California
• Decided: November 5, 2025
• Docket: 2:24-cv-02896
• Status: Unknown

Opinion

1 Samvel Geshgian, Esq. (SBN 300470) Gourgen Babayan, Esq. (SBN 314499) 2 SGGB LAW FIRM, LLP 16530 Ventura Boulevard, Suite 409 3 Encino, California 91436 Telephone: (818) 855-1018 4 Facsimile: (818) 474-0047 Email: sg@sggblaw.com 5 Email: gb@sggblaw.com Attorneys for Plaintiff ROSALVA QUIRARTE 6 Natalie Hernandez, Esq. (SBN 289350) 7 OGLETREE, DEAKINS, NASH, SMOAK & STEWART P.C. 8 Park Tower, Fifteenth Floor 695 Town Center Drive 9 Costa Mesa, CA 9266 Telephone: (714) 800-7900 10 Facsimile: (714) 754-8298 Email: Natalie.Hernandez@ogletree.com 11 Attorneys for Defendant CIOX HEALTH, LLC dba DATAVANT GROUP 12 Lisa Barnett Sween (SBN 191155) 13 Elizabeth R. Weiss (SBN 209181) JACKSON LEWIS P.C. 14 50 California Street, 9th Floor San Francisco, California 94111-4615 15 Telephone: (415) 394-9400 Facsimile: (415) 394-9401 16 Email: Lisa.Sween@jacksonlewis.com Email: Elizabeth.Weiss@jacksonlewis.com 17 Attorneys for Defendant MATRIX ABSENCE MANAGEMENT, INC. 18 19 UNITED STATES DISTRICT COURT 20 EASTERN DISTRICT OF CALIFORNIA

21 ROSALVA QUIRARTE, and individual, Case No. 2:24-cv-02896-DC-CKD Plaintiff, 22 STIPULATED PROTECTIVE ORDER v. 23 WITH MODIFICATION BY THE CIOX HEALTH, LLC, doing business as COURT 24 DATAVANT GROUP, a Delaware Corporation; MATRIX ABSENCE Complaint Filed: 09/10/2024 25 MANAGEMENT, INC., a Delaware Removal Filed: 10/18/2024 Corporation; and DOES 1 through 20, FAC Filed: 12/03/2024 26 inclusive, Trial Date: Not Set 27 Defendants. 28 1 1. PURPOSES AND LIMITATIONS 2 A. Disclosure and discovery activity in this action are likely to involve production of 3 confidential, proprietary, or private information for which special protection from public 4 disclosure and 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 following Stipulated 6 Protective Order. The parties acknowledge that this Order does not confer blanket protections on 7 all disclosures or responses to discovery and that the protection it affords from public disclosure 8 and use extends only to the limited information or items that are entitled to confidential treatment 9 under the applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, 10 below, that this Stipulated Protective Order does not entitle them to file confidential information 11 under seal; Civil Local Rule 141 sets forth the procedures that must be followed and the standards 12 that will be applied when a party seeks permission from the court to file material under seal. 13 2. DEFINITIONS 14 2.1 Challenging Party: a Party or Non-Party that challenges the designation of 15 information or items under this Order. 16 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is 17 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule 18 of Civil Procedure 26(c). 19 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as 20 well as their support staff). 21 2.4 Designating Party: a Party or Non-Party that designates information or items that it 22 produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 23 2.5 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 other things, 25 testimony, transcripts, and tangible things), that are produced or generated in disclosures or 26 responses to discovery in this matter. 27 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to 28 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 1 consultant in this action. 2 2.7 House Counsel: attorneys who are employees of a party to this action. House 3 Counsel does not include Outside Counsel of Record or any other outside counsel. 4 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal 5 entity not named as a Party to this action. 6 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this 7 action but are retained to represent or advise a party to this action. 8 2.10 Party: any party to this action, including all of its officers, directors, employees, 9 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 10 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 11 Material in this action. 12 2.12 Professional Vendors: persons or entities that provide litigation support services 13 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and 14 organizing, storing, or retrieving data in any form or medium) and their employees and 15 subcontractors. 16 2.13 Protected Material: any Disclosure or Discovery Material that is designated as 17 “CONFIDENTIAL” and that consists ofnon-public information relating to Plaintiff’s medical 18 condition and/or disability, Plaintiff’s related accommodation requests, administration and 19 processing thereof, and communications regarding the foregoing. 20 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a 21 Producing Party. 22 3. SCOPE 23 B. The protections conferred by this Stipulation and Order cover not only Protected 24 Material (as defined above), but also (1) any information copied or extracted from Protected 25 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any 26 testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected 27 Material. However, the protections conferred by this Stipulation and Order do not cover the 28 following information: (a) any information that is in the public domain at the time of disclosure to 1 a Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as 2 a result of publication not involving a violation of this Order, including becoming part of the public 3 record through trial or otherwise; and (b) any information known to the Receiving Party prior to 4 the disclosure or obtained by the Receiving Party after the disclosure from a source who obtained 5 the information lawfully and under no obligation of confidentiality to the Designating Party. Any 6 use of Protected Material at trial shall be governed by a separate agreement or order. 7 4. DURATION 8 C. Even after final disposition of this litigation, the confidentiality obligations 9 imposed by this Order shall remain in effect until a Designating Party agrees otherwise in writing 10 or a court order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal 11 of all claims and defenses in this action, with or without prejudice; and (2) final judgment herein 12 after the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this 13 action, including the time limits for filing any motions or applications for extension of time 14 pursuant to applicable law. 15 5. DESIGNATING PROTECTED MATERIAL 16 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party 17 or Non-Party that designates information or items for protection under this Order must take care 18 to limit any such designation to specific material that qualifies under the appropriate standards. 19 The Designating Party must designate for protection only those parts of material, documents, 20 items, or oral or written communications that qualify – so that other portions of the material, 21 documents, items, or communications for which protection is not warranted are not swept 22 unjustifiably within the ambit of this Order. 23 D. Mass, indiscriminate, or routinized designations are prohibited. Designations that 24 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., to 25 unnecessarily encumber or retard the case development process or to impose unnecessary expenses 26 and burdens on other parties) expose the Designating Party to sanctions. 27 If it comes to a Designating Party’s attention that information or items that it designated 28 for protection do not qualify for protection, that Designating Party must promptly notify all other 1 Parties that it is withdrawing the mistaken designation. 2 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order 3 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, 4 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so 5 designated before the material is disclosed or produced. 6 E. Designation in conformity with this Order requires: 7 (a) For information in documentary form (e.g., paper or electronic documents, but 8 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 9 affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a portion 10 or portions of the material on a page qualifies for protection, the Producing Party also must clearly 11 identify the protected portion(s) (e.g., by making appropriate markings in the margins). 12 A Party or Non-Party that makes original documents or materials available for inspection need not 13 designate them for protection until after the inspecting Party has indicated which material it would 14 like copied and produced. During the inspection and before the designation, all of the material 15 made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 16 identified the documents it wants copied and produced, the Producing Party must determine which 17 documents, or portions thereof, qualify for protection under this Order. Then, before producing the 18 specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page 19 that contains Protected Material. If only a portion or portions of the material on a page qualifies 20 for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by 21 making appropriate markings in the margins). 22 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the 23 Designating Party identify on the record, before the close of the deposition, hearing, or other 24 proceeding, all protected testimony. 25 (c) for information produced in some form other than documentary and for any other 26 tangible items, that the Producing Party affix in a prominent place on the exterior of the container 27 or containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a 28 portion or portions of the information or item warrant protection, the Producing Party, to the extent 1 practicable, shall identify the protected portion(s). 2 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 3 designate qualified information or items does not, standing alone, waive the Designating Party’s 4 right to secure protection under this Order for such material. Upon timely correction of a 5 designation, the Receiving Party must make reasonable efforts to assure that the material is treated 6 in accordance with the provisions of this Order. 7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 9 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 10 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic 11 burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to 12 challenge a confidentiality designation by electing not to mount a challenge promptly after the 13 original designation is disclosed. 14 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process 15 by providing written notice of each designation it is challenging and describing the basis for each 16 challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must 17 recite that the challenge to confidentiality is being made in accordance with this specific paragraph 18 of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must 19 begin the process by conferring directly (in voice to voice dialogue; other forms of communication 20 are not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging 21 Party must explain the basis for its belief that the confidentiality designation was not proper and 22 must give the Designating Party an opportunity to review the designated material, to reconsider 23 the circumstances, and, if no change in designation is offered, to explain the basis for the chosen 24 designation. A Challenging Party may proceed to the next stage of the challenge process only if it 25 has engaged in this meet and confer process first or establishes that the Designating Party is 26 unwilling to participate in the meet and confer process in a timely manner. 27 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court 28 intervention, the Designating Party shall file and serve a motion to retain confidentiality under 1 Civil Local Rule 141 (and in compliance with Civil Local Rule 140 if applicable) within 21 days 2 of the initial notice of challenge or within 14 days of the parties agreeing that the meet and confer 3 process will not resolve their dispute, whichever is earlier. Each such motion must be accompanied 4 by a competent declaration affirming that the movant has complied with the meet and confer 5 requirements imposed in the preceding paragraph. Failure by the Designating Party to make such 6 a motion including the required declaration within 21 days (or 14 days, if applicable) shall 7 automatically waive the confidentiality designation for each challenged designation. In addition, 8 the Challenging Party may file a motion challenging a confidentiality designation at any time if 9 there is good cause for doing so, including a challenge to the designation of a deposition transcript 10 or any portions thereof. Any motion brought pursuant to this provision must be accompanied by a 11 competent declaration affirming that the movant has complied with the meet and confer 12 requirements imposed by the preceding paragraph. 13 The burden of persuasion in any such challenge proceeding shall be on the Designating 14 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose 15 unnecessary expenses and burdens on other parties) may expose the Challenging Party to 16 sanctions. Unless the Designating Party has waived the confidentiality designation by failing to 17 file a motion to retain confidentiality as described above, all parties shall continue to afford the 18 material in question the level of protection to which it is entitled under the Producing Party’s 19 designation until the court rules on the challenge. 20 7. ACCESS TO AND USE OF PROTECTED MATERIAL 21 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 22 produced by another Party or by a Non-Party in connection with this case only for prosecuting, 23 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to 24 the categories of persons and under the conditions described in this Order. When the litigation has 25 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL 26 DISPOSITION). 27 Protected Material must be stored and maintained by a Receiving Party at a location and in 28 a secure manner that ensures that access is limited to the persons authorized under this Order. 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered 2 by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any 3 information or item designated “CONFIDENTIAL” only to: 4 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 5 employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the 6 information for this litigation and who have signed the “Acknowledgment and Agreement to Be 7 Bound” that is attached hereto as Exhibit A; 8 (b) the officers, directors, and employees (including House Counsel) of the Receiving 9 Party to whom disclosure is reasonably necessary for this litigation and who have signed the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 12 reasonably necessary for this litigation and who have signed the “Acknowledgment and 13 Agreement to Be Bound” (Exhibit A); 14 (d) the court and its personnel; 15 (e) court reporters and their staff, professional jury or trial consultants, mock jurors, 16 and Professional Vendors to whom disclosure is reasonably necessary for this litigation and who 17 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (f) during their depositions, witnesses in the action to whom disclosure is reasonably 19 necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 20 unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed 21 deposition testimony or exhibits to depositions that reveal Protected Material must be separately 22 bound by the court reporter and may not be disclosed to anyone except as permitted under this 23 Stipulated Protective Order. 24 (g) the author or recipient of a document containing the information or a custodian or 25 other person who otherwise possessed or knew the information. 26 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 27 LITIGATION 28 If a Party is served with a subpoena or a court order issued in other litigation that compels 1 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party 2 must: 3 (a) promptly notify in writing the Designating Party. Such notification shall include a 4 copy of the subpoena or court order; 5 (b) promptly notify in writing the party who caused the subpoena or order to issue in 6 the other litigation that some or all of the material covered by the subpoena or order is subject to 7 this Protective Order. Such notification shall include a copy of this Stipulated Protective Order; 8 and 9 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 10 Designating Party whose Protected Material may be affected. 11 If the Designating Party timely seeks a protective order, the Party served with the subpoena 12 or court order shall not produce any information designated in this action as “CONFIDENTIAL” 13 before a determination by the court from which the subpoena or order issued, unless the Party has 14 obtained the Designating Party’s permission. The Designating Party shall bear the burden and 15 expense of seeking protection in that court of its confidential material – and nothing in these 16 provisions should be construed as authorizing or encouraging a Receiving Party in this action to 17 disobey a lawful directive from another court. 18 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS 19 LITIGATION 20 (a) The terms of this Order are applicable to information produced by a Non-Party in 21 this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in 22 connection with this litigation is protected by the remedies and relief provided by this Order. 23 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking 24 additional protections. 25 (b) In the event that a Party is required, by a valid discovery request, to produce a Non- 26 Party’s confidential information in its possession, and the Party is subject to an agreement with the 27 Non-Party not to produce the Non-Party’s confidential information, then the Party shall: 28 (1) promptly notify in writing the Requesting Party and the Non-Party that some or 1 all of the information requested is subject to a confidentiality agreement with a Non-Party; 2 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order 3 in this litigation, the relevant discovery request(s), and a reasonably specific description of the 4 information requested; and 5 (3) make the information requested available for inspection by the Non-Party. 6 (c) If the Non-Party fails to object or seek a protective order from this court within 14 7 days of receiving the notice and accompanying information, the Receiving Party may produce the 8 Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely 9 seeks a protective order, the Receiving Party shall not produce any information in its possession 10 or control that is subject to the confidentiality agreement with the Non-Party before a 11 determination by the court. Absent a court order to the contrary, the Non-Party shall bear the 12 burden and expense of seeking protection in this court of its Protected Material. 13 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 14 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 15 Material to any person or in any circumstance not authorized under this Stipulated Protective 16 Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the 17 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected 18 Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the 19 terms of this Order, and (d) request such person or persons to execute the “Acknowledgment and 20 Agreement to Be Bound” that is attached hereto as Exhibit A. 21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 22 MATERIAL 23 When a Producing Party gives notice to Receiving Parties that certain inadvertently 24 produced material is subject to a claim of privilege or other protection, the obligations of the 25 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision 26 is not intended to modify whatever procedure may be established in an e-discovery order that 27 provides for production without prior privilege review. Pursuant to Federal Rule of Evidence 28 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a 1 communication or information covered by the attorney-client privilege or work product protection, 2 the parties may incorporate their agreement in the stipulated protective order submitted to the 3 court. 4 12. MISCELLANEOUS 5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to 6 seek its modification by the court in the future. 7 F. 12.2 Right to Assert Other Objections. By stipulating to the entry of this 8 Protective Order no Party waives any right it otherwise would have to object to disclosing or 9 producing any information or item on any ground not addressed in this Stipulated Protective Order. 10 Similarly, no Party waives any right to object on any ground to use in evidence of any of the 11 material covered by this Protective Order. 12 12.3 Filing Protected Material. Without written permission from the Designating Party 13 or a court order secured after appropriate notice to all interested persons, a Party may not file in 14 the public record in this action any Protected Material. A Party that seeks to file under seal any 15 Protected Material must comply with Civil Local Rule 141. Protected Material may only be filed 16 under seal pursuant to a court order authorizing the sealing of the specific Protected Material at 17 issue, and upon the showing required under applicable law. If a Receiving Party's request to file 18 Protected Material under seal pursuant to Civil Local Rule 141 is denied by the court, then the 19 Receiving Party may file the information in the public record pursuant to Civil Local Rule 141 20 unless otherwise instructed by the court. 21 13. FINAL DISPOSITION 22 Within 60 days after the final disposition of this action, as defined in paragraph 4, each 23 Receiving Party must return all Protected Material to the Producing Party or destroy such material. 24 As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 25 summaries, and any other format reproducing or capturing any of the Protected Material. 26 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, 27 motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 28 deposition and trial exhibits, expert reports, attorney work product, and consultant and expert work 1 product, even if such materials contain Protected Material. Any such archival copies that contain 2 or constitute Protected Material remain subject to this Protective Order as set forth in Section 4 3 (DURATION). 4 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 DATED: __10/31/2025_______________ ______/s/ Samvel Geshgian___________ Samvel Geshgian 8 Gourgen Babayan Attorneys for Plaintiff 9 Rosalva Quirarte 10 DATED: __10/31/2025_______________ ______/s/ Natalie Hernandez____________ Natalie Hernandez 11 Attorneys for Defendant Ciox Health, LLC dba Datavant Group 12 DATED: __10/31/2025_______________ ______/s/ Elizabeth R. Weiss___________ 13 Lisa Barnett Sween Elizabeth R. Weiss 14 Attorneys for Defendant Matrix Absence Management, Inc. 15

16 ATTESTATION 17 Counsel for Plaintiff, Samvel Geshgian, authorized submission of his e-signature on this 18 document in writing, by e-mail dated October 31, 2025 at 3:10 PM; and Counsel for Defendant 19 Ciox Health LLC dba Datavant Group authorized submission of her e-signature on this document 20 in writing, by e-mail dated October 31, 2025 at 2:35 PM. 21 22 23 24 25 26 27 28 1 ORDER 2 The Court has reviewed the parties’ stipulated protective order. (ECF No. 39.) The 3 || stipulation comports with the relevant authorities and the court’s applicable local rule. See L.R. 4 | 141.1. The Court APPROVES the protective order, subject to the following clarifications. The 5 || Court’s Local Rules indicate that once an action is closed, it “will not retain jurisdiction over 6 | enforcement of the terms of any protective order filed in that action.” L.R. 141.1(f); see also, 7 | e.g., MD Helicopters, Inc. v. Aerometals, Inc., 2017 WL 495778 (E.D. Cal., Feb. 03, 2017) 8 | (noting that courts in the district generally do not retain jurisdiction for disputes concerning 9 || protective orders after closure of the case). Thus, the Court will not retain jurisdiction over this 10 || protective order once the case is closed. 11 || Dated: November 5, 2025 / a8 } Ht | Ld Sak

13 UNITED STATES MAGISTRATE JUDGE 14 15 || 5, quir.2896.24 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 penalty of perjury that I have read in its entirety and 5 understand the Stipulated Protective Order that was issued by the United States District Court for 6 the Eastern District of California on __________________, 2025, in the case of Rosalva Quirarte 7 v. Ciox Health, LLC dba Datavant Group, Matrix Absence Management, Inc., Case No. 2:24-Cv- 8 02896-DC-CKD, I agree to comply with and to be bound by all the terms of this Stipulated 9 Protective Order and I understand and acknowledge that failure to so comply could expose me to 10 sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in 11 any manner any information or item that is subject to this Stipulated Protective Order to any person 12 or entity except in strict compliance with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court for the 14 Eastern District of California for the purpose of enforcing the terms of this Stipulated Protective 15 Order, even if such enforcement proceedings occur after termination of this action. 16 I hereby appoint __________________________ [print or type full name] of 17 _______________________________________ [print or type full address and telephone number] 18 as my California agent for service of process in connection with this action or any proceedings 19 related to enforcement of this Stipulated Protective Order. 20 Date: ______________________________________ 21 City and State where sworn and signed: _________________________________ 22 Printed name: _______________________________ 23 24 Signature: __________________________________

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