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UA
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
dul-19-2013 4:55 pm
Case Number: CGC-12-523951
Filing Date: Jul-19-2013 4:54
Filed by: GINA GONZALES
Juke Box: 001 Image: 04133492
ORDER
CHARLES HARB et al VS. DEREK SENE et al
001004133492
Instructions:
Please place this sheet on top of the document to be scanned.ce
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STEPHEN M. HAYES (SBN 83583)
shayes@hayesscolt,com
STEPHEN P, ELLINGSON (SBN 136505)
setlingson@hayesscott.com
HAYES SCOTT BONINO ELLINGSON & McLAY, LLP
203 Redwood Shores Parkway, Suite 480
Redwood City, California 94065
Telephone: 650,637.9100
Facsimile: 650.637.8071
Altomey for Defendants
DEREK, SENE and STATE FARM GENERAL
INSURANCE COMPANY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO
CHARLES HARB, and the CHARLES HARB CASE NO. CGC-£2-523951
REVOCABLE LIVING TRUST,
STIPULATION AND ORDER
REGARDING NON-DISCLOSURE OF
vs. CONFIDENTIAL AND PROPRIETARY
DOCUMENTS
Plaintiffs,
DEREK SENE, STATE FARM GENERAL
INSURANCE COMPANY, an Illinois
corporation, and DOES 1-50 inclusive,
Defendants.
iL
STIPULATION AND PROTECTIVE ORDER REGARDING
LODUCTION OF DOCUMENTS
Defendants STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY
(STATE FARM”) and DEREK SENE (“SENE”) and plaintiffs CHARLES HARB and THE
CHARLES HARB REVOCABLE LIVING TRUST (collectively “HARB") horeby stipulate to
a1. -
BARB Y, STATE FARM, et al. - CASE NO. CGC-12-523951
* STIPULATED PROTECTIVE ORDERee a AH wa we
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the following protective order with respect to and to accommodate production of documents in
this action,
In the event the parties agree to produce any Documents pursuant to this stipulation in
advance of the comt’s execution of the order, the parties hereby agrse to fully abide by their
respective rights and obligations herein as a stipulation and contract and as though this
stipulation was approved and ordered by the court.
I.
DESIGNATION OF MATERIALS AS CONFIDENTIAL
@) “Confidential” materials shall include only such information as the Producing or
Designating Patty in good faith contends should be protected pursuant to this
Protective Order on the grounds that the information is properly subject to protection
under existing California o federal law.
(b) In making the designation of materials puravant to this Protective Order, the
Producing or Designating Party shall give due consideration to whether the
information contained in the materials (1) has been produced, disclosed or made
available io the pubfic in the past, (2) has been published, communicated or
disseminated to others not obligated to maintain the confidentiality of the information
coritained therein, (3) has not been preserved or maintained in a manner calculated to
preserve its confidentiality, or (4) is available fiom a third party or commercial source!
that is not obligated to maintain its confidentiality or privacy, The Producing or
Designating party shatl also give due consideration to the age of the materials.
(©) The protection of this Protective Order may be invoked with respect to materials
in the following manner;
@~ ——_ Doctnnents when produced or otherwise designated shall bear the clear
and legible designation “Confidential” on each page of the document,
except that in the case of multi-page documents bound together by staple
HARB Y, STATE FARM, etal. ~ CASE NO. CGC-12-52395)
STIPULATED PROTECTIVE ORDERSe UAH Bw we
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information without marking it with an appropriate legend, the Producing Party or a
Designating Party shalt promptly notify the recciving party that the information
should be treated in accordance with the terms of this Protective Order, and shall
forward appropriately stamped copies of the items in question, Within five (5) days
of the receipt of substitute copies, the receiving party shall retum the previously
unmarked items and all copies thereof. The inadvertent disclosure shall not be
Ifany Producing Party inadvertently produces or discloses any “Confidential”
or other permanent binding, the “Confidentia!" legend need only be
affixed to the first page in order for the entire document to be treated as
“Confidential.” Documents produced prior to the entry of this Protective
Otder may be designated as “Confidential” within thirty (30) days after
entry, and documents produced by non-parties may be designated
“Confidential” by a Party within thirty (30) days after such production.
As to discovery requests or the responses thereto, the pages of such
requests of responses containing “Confidential” materials shall be so
marked, and the first page of the requests or responses shall bear a legend
substantially stating that “This Document Contains Confidential
Material”;
AS to deposition testimony, “Confidential” treatment may be invoked by:
(1) declaring the-same on the record at the deposition with instructions to
80 designate thé cover of the deposition transcript, or (2) designating
specific pages as “Confidential” and serving such designations within
thirty (30) days of receipt of the transcript of the deposition in which the
dosignations are made. Ali deposition testimony shall be treated as
“Confidential” pending receipt of 9 transcript of the deposition.
-3--
HHARB V. STATE FARM, et al. - CASE NO, CGC-12-523951
* STIPULATED PROTECTIVE ORDERCe NAA Rw! De
Ss
deemed a waiver of confidentiality, and such designation shall be shade aS Soon as
possible after the discovery of the inadvertent production of disclosure.
In.
CHALLENGES TO “CONFIDENTIAL” DESIGNATION
(a) Any Party believing materials designated as “Confidential” by another is to!
entitled to such designation shal! notify the Produciag or Designating Party of tha
belief in writing, provide a brief statement of the basis for that belief with service on|
all other Parlies, and allow ten (10) days for the Producing or Designating Party to
respond,
{b) If a Producing or Designating Party docs not modify its designation of the
materials in response to a nolice pursuant to Paragraph 3(a) of this Protective Order,
then the Party challenging the “confidential” designation may move the court for an
order modifying or removing such designation, To maintain “Confidential” status
the burden shall be on the proponent of confidentiality to show that the matetial oy
" information is entitled td protection under applicable taw. Unless and until @
“Confidential” designation is voluntarily withdrawn by the Producing or Designating)
Party, or the cowt issues an order modifying or removing such designation, thd
provisions of the Protective Order shall continue to apply.
IV.
PERSONS AU’ THORIZED TO TAKE CUSTODY
Only attorneys for parties of record, and law clerks, secretarics, translators, and qualified
Stenographers for sald attorneys, and any experts actually hired for consultation and/or testimony
in connection with this case, shall be allowed to view and retain custody of copes of the
“Documents” or notes taken therefrom.
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HARB V, STATE FARM, et al, - CASE NO. CGC-12-523951
* STIPULATED PROTECTIVE ORDERCe INH Bw wv
10
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PROCEDURE FOR GRANTING CUSTODY
Prior to granting custody of copies of the subject Documents or ‘notes taken therefrom,
each person who is to take such custody shall be brought within the personal jurisdiction of the
Court, including its contempt power, by signing a copy of this order signifying agreement to its
provisions and consent 10 jurisdiction of the Court over his or her person for any ‘proceedings
involving alleged improper disclosures, Each such signatore shall be made under penalty of
perjury. .
The failure to have eack person sign a copy of this order prior io granting custody of
copies of the subject Documents or notes taken therefrom, will result in the prohibition of the
parties using these Documents for any purpose including this case.
VI
VIEWING RECORD AND AGREEMENT
No person shall be allowed or ainthorized to examine any portion of said Documents or
notes arising therefrom, or to discuss the contents of either, until such persons has:
(1) Read this Court Order; and
(2) Completed and signed the “Viewing and Custody Record and Agreement”
attached hereto as Exhibit “A”.
vil,
JURISDICTION
Each person signing the “Viewing and Custody Record and Agreement” thereby agrees
to be subject to the jurisdiction of this Court for contempt and other appropriate proceedings in
the event of an alleged violation of this Protective Order,
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HARB V. STATE FARM, et a}, - CASE NO. CGC-12-523951
STIMULATED PROTECTIVE ORDER
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VIL,
NON-DISCLOSURE
No person anthorized hereunder to view copies of the Documents of to.make notes
therefrom, may disclose any portion of the subject matte or contents of either any person not
authorized hereunder,
x,
(ON-DISSEI [ATE
The Documents, copies of any portion of the same, contents of the Documents itself and
all notes arising from examination of seid Documents, as well as discussions of the contents
thereof, shal! be used only in connection with the present case of Harb y. State Farm et al. San
Francisco Superior Court Case No, CGC-12-523951, and shall be used for no other purposes
whatsoever including, but not limited to, other lawsuits, actions, claims or demands,
Xx,
USE IN COURT PROCEEDIN' GS ~ JILING OF COURT PAPERS
a) Nothing contained in this Protective Order shall be construed to préjudice any
patty’s right to use at trial or in any hearing before the Court, any confidential information,
provided that reasonable notice of the intended use of such materials be given to ail counsel o
record in order to enable the parties to arrange for appropriate safeguards, and provide that the
mules applicable to sealing records, as addressed below are followed, Likewise, nothing in this
Protective Order shall be dispositive of any issues of relevance, discoverability or adtnissibility.
. b) The submission of any materials designated as “Confidential” pursuant to
this Protective Order to the Court in the litigation must comply with California Rules of Court
(CRO) 2.550 and 2.551, and 8.46 to the extent applicable, If the materials are required to be
kept confidential by !aw, or submitted in connection with discovery motions or proceedings, no
court order is required (CRC 2.550(a)(2) and (3)), However, if the materials are submitted for
use at trial or as the basis for adjudication of matters other than discovery motions or
proceedings, a court order scaling the documents is required and may only be obtained by careful
=Ge.
HARD V, STATE FARM, et ol. - CASE NO, CGC-12-52395]
STIPULATED PROTECTIVE ORDERSC ee WM HOH AB wD
compliance with the procedure set forth in CRC 2,551, The-parties vinteestnd that failure to
comply with the procedural requirements of 2.951 -or faillare to present eviderise sulficient to
support the findings in CRC 2,550(d), may result ity the placement of'ccnfidential materials
the public file. The partles further understand that no-sealing order will be fssuied solely on the
basis of the existence and applicability of (his Protective Order (CRC 2.551 (ad).
XT,
NON-WAIVER
The production of the subjeet Documents for inspection, Viewing and eustody shall nat
cofistilute awaiver of the parties? fight-to:claim in this lawsuit or otherwise, that said Documents!
ornny documeits described therein ite privileged or otherwise hon-discoverable or admissible,
xIL
SURRENDER OF DOCUMENTS
At the conclusion of the subject litigation, all Documents provided, and any cdpies
thereof, under this protective order shall be returned to the.respective parties’ counsel, ‘The
Documents are to be retutned as soon as possible and no Jater than seven (7) days from the date
of the dismissal of the.action. :
ITIS.SO STIPULATED:
Dated: hugy 28,2013 LAW OFFICES OF HAROLD JAUTE
By: Huth in Olaf !
HAROLM. JAPFE 7
Attomey for Plaintiffs Charles Harb aud Chartes|
Harb Revocable Living Trust
HAYLS-BONINO ELLINGSON MCLAY & SCOTT, ELF
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By: Os a ibe
‘STEPHEN B. ELLINGSON
DARA M, TANG’
Attorneys for Delencanis Derek Sene and State
Farin General Insurauéé Company
HARD'V, STATE FARM, ct ai “ASE NO: CGC-]2+52395 1
STIPULATED PROTECTIVE ORDER2 ry Aw eon ua
me
Boo 8S
Dated;
ORDER “s
PURSUANT TO STIPULATION, IT IS SO ORDERED.
ERNEST H. GOLDSMITH
HARB V, STATE FARM, et al. — CASE NO. CGC-J2-523951
" STIPULATED PROTECTIVE ORDERSO sa AH Aw
EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
[print or type full name}, of
{print or type full address},
declare under penalty of perjury that I haye read in its entirety and understand the Stipulated
Protective Order that was issued by the California Superior Court, City and County of San
Francisca, on in the case of Harb v, State Farm, et al. Case No, CGC-12-523951,
Tagree to comply with and 10 be bound by all the terms of this Stipulated Protective Order and I
understand and acknowledge that failure to so comply could expose mic to sanctions and
punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner
any information or item that is subject to this Stipulated Protective Order to any person or entity
except in striet compliance with the provisions of this Order,
I further agree to submit to the jurisdiction of the above-referenced Court for the purpose
of enforcing the terms of this Stipulated Protective Order, even if such enforcement proceedings
occur after termination of this action,
Date: ee
City and State where signed:
Signature; .
Printed Name: a
ase 9.
HARB V, STATE FARM, ot al. - CASE NO. CGC-]2-523951
STIPULATED PROTECTIVE ORDER
Preview
UA SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet dul-19-2013 4:55 pm Case Number: CGC-12-523951 Filing Date: Jul-19-2013 4:54 Filed by: GINA GONZALES Juke Box: 001 Image: 04133492 ORDER CHARLES HARB et al VS. DEREK SENE et al 001004133492 Instructions: Please place this sheet on top of the document to be scanned.ce S = oo oO 3 = o STEPHEN M. HAYES (SBN 83583) shayes@hayesscolt,com STEPHEN P, ELLINGSON (SBN 136505) setlingson@hayesscott.com HAYES SCOTT BONINO ELLINGSON & McLAY, LLP 203 Redwood Shores Parkway, Suite 480 Redwood City, California 94065 Telephone: 650,637.9100 Facsimile: 650.637.8071 Altomey for Defendants DEREK, SENE and STATE FARM GENERAL INSURANCE COMPANY SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO CHARLES HARB, and the CHARLES HARB CASE NO. CGC-£2-523951 REVOCABLE LIVING TRUST, STIPULATION AND ORDER REGARDING NON-DISCLOSURE OF vs. CONFIDENTIAL AND PROPRIETARY DOCUMENTS Plaintiffs, DEREK SENE, STATE FARM GENERAL INSURANCE COMPANY, an Illinois corporation, and DOES 1-50 inclusive, Defendants. iL STIPULATION AND PROTECTIVE ORDER REGARDING LODUCTION OF DOCUMENTS Defendants STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY (STATE FARM”) and DEREK SENE (“SENE”) and plaintiffs CHARLES HARB and THE CHARLES HARB REVOCABLE LIVING TRUST (collectively “HARB") horeby stipulate to a1. - BARB Y, STATE FARM, et al. - CASE NO. CGC-12-523951 * STIPULATED PROTECTIVE ORDERee a AH wa we 10 the following protective order with respect to and to accommodate production of documents in this action, In the event the parties agree to produce any Documents pursuant to this stipulation in advance of the comt’s execution of the order, the parties hereby agrse to fully abide by their respective rights and obligations herein as a stipulation and contract and as though this stipulation was approved and ordered by the court. I. DESIGNATION OF MATERIALS AS CONFIDENTIAL @) “Confidential” materials shall include only such information as the Producing or Designating Patty in good faith contends should be protected pursuant to this Protective Order on the grounds that the information is properly subject to protection under existing California o federal law. (b) In making the designation of materials puravant to this Protective Order, the Producing or Designating Party shall give due consideration to whether the information contained in the materials (1) has been produced, disclosed or made available io the pubfic in the past, (2) has been published, communicated or disseminated to others not obligated to maintain the confidentiality of the information coritained therein, (3) has not been preserved or maintained in a manner calculated to preserve its confidentiality, or (4) is available fiom a third party or commercial source! that is not obligated to maintain its confidentiality or privacy, The Producing or Designating party shatl also give due consideration to the age of the materials. (©) The protection of this Protective Order may be invoked with respect to materials in the following manner; @~ ——_ Doctnnents when produced or otherwise designated shall bear the clear and legible designation “Confidential” on each page of the document, except that in the case of multi-page documents bound together by staple HARB Y, STATE FARM, etal. ~ CASE NO. CGC-12-52395) STIPULATED PROTECTIVE ORDERSe UAH Bw we Giy Gi) information without marking it with an appropriate legend, the Producing Party or a Designating Party shalt promptly notify the recciving party that the information should be treated in accordance with the terms of this Protective Order, and shall forward appropriately stamped copies of the items in question, Within five (5) days of the receipt of substitute copies, the receiving party shall retum the previously unmarked items and all copies thereof. The inadvertent disclosure shall not be Ifany Producing Party inadvertently produces or discloses any “Confidential” or other permanent binding, the “Confidentia!" legend need only be affixed to the first page in order for the entire document to be treated as “Confidential.” Documents produced prior to the entry of this Protective Otder may be designated as “Confidential” within thirty (30) days after entry, and documents produced by non-parties may be designated “Confidential” by a Party within thirty (30) days after such production. As to discovery requests or the responses thereto, the pages of such requests of responses containing “Confidential” materials shall be so marked, and the first page of the requests or responses shall bear a legend substantially stating that “This Document Contains Confidential Material”; AS to deposition testimony, “Confidential” treatment may be invoked by: (1) declaring the-same on the record at the deposition with instructions to 80 designate thé cover of the deposition transcript, or (2) designating specific pages as “Confidential” and serving such designations within thirty (30) days of receipt of the transcript of the deposition in which the dosignations are made. Ali deposition testimony shall be treated as “Confidential” pending receipt of 9 transcript of the deposition. -3-- HHARB V. STATE FARM, et al. - CASE NO, CGC-12-523951 * STIPULATED PROTECTIVE ORDERCe NAA Rw! De Ss deemed a waiver of confidentiality, and such designation shall be shade aS Soon as possible after the discovery of the inadvertent production of disclosure. In. CHALLENGES TO “CONFIDENTIAL” DESIGNATION (a) Any Party believing materials designated as “Confidential” by another is to! entitled to such designation shal! notify the Produciag or Designating Party of tha belief in writing, provide a brief statement of the basis for that belief with service on| all other Parlies, and allow ten (10) days for the Producing or Designating Party to respond, {b) If a Producing or Designating Party docs not modify its designation of the materials in response to a nolice pursuant to Paragraph 3(a) of this Protective Order, then the Party challenging the “confidential” designation may move the court for an order modifying or removing such designation, To maintain “Confidential” status the burden shall be on the proponent of confidentiality to show that the matetial oy " information is entitled td protection under applicable taw. Unless and until @ “Confidential” designation is voluntarily withdrawn by the Producing or Designating) Party, or the cowt issues an order modifying or removing such designation, thd provisions of the Protective Order shall continue to apply. IV. PERSONS AU’ THORIZED TO TAKE CUSTODY Only attorneys for parties of record, and law clerks, secretarics, translators, and qualified Stenographers for sald attorneys, and any experts actually hired for consultation and/or testimony in connection with this case, shall be allowed to view and retain custody of copes of the “Documents” or notes taken therefrom. -4- HARB V, STATE FARM, et al, - CASE NO. CGC-12-523951 * STIPULATED PROTECTIVE ORDERCe INH Bw wv 10 v : PROCEDURE FOR GRANTING CUSTODY Prior to granting custody of copies of the subject Documents or ‘notes taken therefrom, each person who is to take such custody shall be brought within the personal jurisdiction of the Court, including its contempt power, by signing a copy of this order signifying agreement to its provisions and consent 10 jurisdiction of the Court over his or her person for any ‘proceedings involving alleged improper disclosures, Each such signatore shall be made under penalty of perjury. . The failure to have eack person sign a copy of this order prior io granting custody of copies of the subject Documents or notes taken therefrom, will result in the prohibition of the parties using these Documents for any purpose including this case. VI VIEWING RECORD AND AGREEMENT No person shall be allowed or ainthorized to examine any portion of said Documents or notes arising therefrom, or to discuss the contents of either, until such persons has: (1) Read this Court Order; and (2) Completed and signed the “Viewing and Custody Record and Agreement” attached hereto as Exhibit “A”. vil, JURISDICTION Each person signing the “Viewing and Custody Record and Agreement” thereby agrees to be subject to the jurisdiction of this Court for contempt and other appropriate proceedings in the event of an alleged violation of this Protective Order, MY Hl ie - “Se HARB V. STATE FARM, et a}, - CASE NO. CGC-12-523951 STIMULATED PROTECTIVE ORDER j i I t | | |em AYA eH B&D 10 VIL, NON-DISCLOSURE No person anthorized hereunder to view copies of the Documents of to.make notes therefrom, may disclose any portion of the subject matte or contents of either any person not authorized hereunder, x, (ON-DISSEI [ATE The Documents, copies of any portion of the same, contents of the Documents itself and all notes arising from examination of seid Documents, as well as discussions of the contents thereof, shal! be used only in connection with the present case of Harb y. State Farm et al. San Francisco Superior Court Case No, CGC-12-523951, and shall be used for no other purposes whatsoever including, but not limited to, other lawsuits, actions, claims or demands, Xx, USE IN COURT PROCEEDIN' GS ~ JILING OF COURT PAPERS a) Nothing contained in this Protective Order shall be construed to préjudice any patty’s right to use at trial or in any hearing before the Court, any confidential information, provided that reasonable notice of the intended use of such materials be given to ail counsel o record in order to enable the parties to arrange for appropriate safeguards, and provide that the mules applicable to sealing records, as addressed below are followed, Likewise, nothing in this Protective Order shall be dispositive of any issues of relevance, discoverability or adtnissibility. . b) The submission of any materials designated as “Confidential” pursuant to this Protective Order to the Court in the litigation must comply with California Rules of Court (CRO) 2.550 and 2.551, and 8.46 to the extent applicable, If the materials are required to be kept confidential by !aw, or submitted in connection with discovery motions or proceedings, no court order is required (CRC 2.550(a)(2) and (3)), However, if the materials are submitted for use at trial or as the basis for adjudication of matters other than discovery motions or proceedings, a court order scaling the documents is required and may only be obtained by careful =Ge. HARD V, STATE FARM, et ol. - CASE NO, CGC-12-52395] STIPULATED PROTECTIVE ORDERSC ee WM HOH AB wD compliance with the procedure set forth in CRC 2,551, The-parties vinteestnd that failure to comply with the procedural requirements of 2.951 -or faillare to present eviderise sulficient to support the findings in CRC 2,550(d), may result ity the placement of'ccnfidential materials the public file. The partles further understand that no-sealing order will be fssuied solely on the basis of the existence and applicability of (his Protective Order (CRC 2.551 (ad). XT, NON-WAIVER The production of the subjeet Documents for inspection, Viewing and eustody shall nat cofistilute awaiver of the parties? fight-to:claim in this lawsuit or otherwise, that said Documents! ornny documeits described therein ite privileged or otherwise hon-discoverable or admissible, xIL SURRENDER OF DOCUMENTS At the conclusion of the subject litigation, all Documents provided, and any cdpies thereof, under this protective order shall be returned to the.respective parties’ counsel, ‘The Documents are to be retutned as soon as possible and no Jater than seven (7) days from the date of the dismissal of the.action. : ITIS.SO STIPULATED: Dated: hugy 28,2013 LAW OFFICES OF HAROLD JAUTE By: Huth in Olaf ! HAROLM. JAPFE 7 Attomey for Plaintiffs Charles Harb aud Chartes| Harb Revocable Living Trust HAYLS-BONINO ELLINGSON MCLAY & SCOTT, ELF a } i . dda { By: Os a ibe ‘STEPHEN B. ELLINGSON DARA M, TANG’ Attorneys for Delencanis Derek Sene and State Farin General Insurauéé Company HARD'V, STATE FARM, ct ai “ASE NO: CGC-]2+52395 1 STIPULATED PROTECTIVE ORDER2 ry Aw eon ua me Boo 8S Dated; ORDER “s PURSUANT TO STIPULATION, IT IS SO ORDERED. ERNEST H. GOLDSMITH HARB V, STATE FARM, et al. — CASE NO. CGC-J2-523951 " STIPULATED PROTECTIVE ORDERSO sa AH Aw EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND [print or type full name}, of {print or type full address}, declare under penalty of perjury that I haye read in its entirety and understand the Stipulated Protective Order that was issued by the California Superior Court, City and County of San Francisca, on in the case of Harb v, State Farm, et al. Case No, CGC-12-523951, Tagree to comply with and 10 be bound by all the terms of this Stipulated Protective Order and I understand and acknowledge that failure to so comply could expose mic to sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner any information or item that is subject to this Stipulated Protective Order to any person or entity except in striet compliance with the provisions of this Order, I further agree to submit to the jurisdiction of the above-referenced Court for the purpose of enforcing the terms of this Stipulated Protective Order, even if such enforcement proceedings occur after termination of this action, Date: ee City and State where signed: Signature; . Printed Name: a ase 9. HARB V, STATE FARM, ot al. - CASE NO. CGC-]2-523951 STIPULATED PROTECTIVE ORDER