Iroquois Master Fund, Ltd. v. Global ePoint, Inc.

Filing 98

PROTECTIVE ORDER by Magistrate Judge Suzanne H. Segal re Notice of Lodging 97 . (See document for details). (mr)

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JOHN H. DONBOLI(SBN: 205218) DONBOLI LAW GROUP,APC 2 11682 El Camino Real, Suite 100 San Diego, CA 92130 3 Telephone:(858)252-2015 Facsimile:(858)724-1490 1 4 5 Attorneys for Defendant: GLOBAL EPOINT,INC. 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 13 14 15 IROQUOIS MASTER FUND,LTD., CASE NO.2:08-cv-07761 UA(SSx) Plaintiff and Judgment Creditor, ~ [~R8~8SL~'D]'STIPULATED PROTECTIVE ORDER vs. [DISCOVERY DOCUMENT: REFERRED TO MAGISTRATE JUDGE SUZANNE H. SEGAL] GLOBAL ePOINT,Inc. 16 Defendants. 17 Magistrate Judge: Hon. Suzanne H. Segal 18 19 2 0 21 PURPOSES AND LIMITATIONS 22 Discovery in this action is likely to involve production of confidential, 23 24 proprietary or private information for which special protection from public 25 disclosure and from use for any purpose other than prosecuting this litigation may 2 6 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 27 28 -1STIl'ULATED PROTECTNE ORDER 1 enter the following Stipulated Protective Order. The parties acknowledge that this 2 Order does not confer blanket protections on all disclosures or responses to 3 4 discovery and that the protection it affords from public disclosure and use extends 5 only to the limited information or items that are entitled to confidential treatment 6 under the applicable legal principles. 7 8 9 GOOD CAUSE STATEMENT This action is likely to involve confidential settlement agreements wherein 10 third parties' rights to privacy are at issue and other financial information for 11 12 which special protection from public disclosure and from use for any purpose other l3 than prosecution ofthis action is warranted. l4 Such confdential and proprietary materials and information may consist of, l5 16 among other things, confidential settlement agreements (including information 17 implicating privacy rights of third parties), financial statements, and information 18 otherwise generally unavailable to the public, or which maybe privileged or 19 20 otherwise protected from disclosure under state or federal statutes, court rules, case 21 decisions, or common law. Accordingly, to expedite the flow of information, to 22 23 facilitate the prompt resolution of disputes over confidentiality of discovery 24 materials, to adequately protect information the parties are entitled to keep 25 confidential, to ensure that the parties are permitted reasonable necessary uses of 2 6 27 such material in prosecuting this litigation, to address their handling at the end of 28 -2STIPULATGD PROTECTIVE ORDER 1 the litigation, and serve the ends ofjustice, a protective order for such information 2 is justified. in this matter. It is the intent of the parties that information will not be 3 4 designated as confidential for tactical reasons and that nothing be so designated 5 without a good faith belief that it has been maintained in a confidential, non-public 6 manner, and there is good cause why it should not be part ofthe public record of 7 8 this case. 9 1. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 10 SEAL 11 12 l3 The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle them to file confidential information 14 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 15 l6 and. the standards that will be applied when a party seeks permission from the court l7 to file material under seal. I8 There is a strong presumption that the public has a right of access to judicial 19 20 proceedings and records in civil cases. I.n connection with non-dispositive motions, 21 good cause must be shown to support a filing under seal. See Kamakana v, City 22 23 and County ofHonolulu,447 F.3d 1172, 1176 (9th Cir. 2006),Phillips v. Gen. 24 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony 25 ~lectrics, Inc., 187 F.R.D. 576, 577(E.D. Wis. 1999)(even stipulated protective 2 6 27 orders require good cause showing), and a specific showing of good cause or 28 -3S"PIPULATBD PROTECTIVE ORDCR 1 compelling reasons with proper evidentiary support and legal justification, must be 2 made with respect to Protected Material that a party seeks to file under seal. The 3 4 parties' mere designation of Disclosure or Discovery Material as S CONFIDENTIAL does not— without the submission of competent evidence by 6 declaration, establishing that the material sought to be filed under seal qualifies as 7 8 9 confidential, privileged, or otherwise protectable—constitute good cause. Further, if a party requests sealing related to a dispositive motion or trial, 10 then compelling reasons, not only good cause, for the sealing must be shown, and 11 12 the relief sought shall be narrowly tailored to serve the specific intet•est to be 13 protected. See Pintos v. Pacific Creditors Ass'n., 605 F.3d 665,677-79(9th Cir. 14 15 2010). For each item or type ofinformation, document, or thing sought to be filed 16 or introduced under seal in connection with a dispositive motion or trial, the party 17 seeking protection must articulate compelling reasons, supported by specific facts 18 19 and legal justification, for the requested sealing order. Again, competent evidence 20 supporting the application to file documents under seal must be provided by 21 declaration. 22 23 24 25 Any document that is not confidential, privileged, or otherwise protectable in its entirety will not be filed under seal if the confidential portions can be redacted. If documents can be redacted, then a redacted version for public viewing, 26 27 omitting only the confidential, privileged, or otherwise protectable portions ofthe 28 -4STIPULATED PROTECTIVE ORDER 1 document, shall be filed. Any application that seeks to file documents under seal in 2 their entirety should include an explanation of why redaction is not feasible. 3 2 . 4 5 DEFINITIONS 2 Action: This pending federal lawsuit, Iroquois Master Fund, Ltd v. .1 6 Global. ePoint, Inc, Case No. 2:08-cv-07761 UA (SSx). 7 2 Challen in~Pa~-tx: a Party or Non-Party that challenges the .2 8 9 designation of information or items under this Order. 10 2 "CONFIDENTIAL" Information or Items: information (regardless of .3 11 12 how it is generated, stored or maintained) or tangible things that qualify for 13 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 14 the Good Cause Statement. 15 2 Counsel: Outside Counsel of Record and House Counsel(as well as their .4 16 17 support staff. 18 2 Desi natin~artX: a Party or Non-Party that designates information or .5 19 items that it produces in disclosures or in responses to discovery as 2 0 21 " CONFIDENTIAL." 22 2 Disclosure or Discovery Material: all items or information, regardless .6 23 of the medium oi• manner in which it is generated, stored, or maintained (including, 24 25 2 6 27 I among other things, testimony, transcripts, and tangible things), that are produced ~ or generated in disclosures or responses to discovery in this matter. 28 -sS9'IPULATED PROTCCTIVE ORDER ]. 2.7 Exert: a person with specialized knowledge or experience in a 2 Matter pertinent to the litigation who has been retained by a Party or its counsel to 3 4 5 serve as an expert witness or as a consultant in this Action. 2.8 House Counsel: attorneys who are employees of a party to this 6 Action. House Counsel does not include Outside Counsel of Record or any other 7 8 9 outside counsel. 2 Non-Party: any natural person, partnership, corporation, association or .9 ]0 other legal entity not named as a Party to this action. 11 12 13 2 .10 Outside Counsel ofRecord: attorneys who are not employees of a party to this Action but are retained to represent or advise a party to this Action 14 and have appeared in this Action on behalf of that party or are affiliated with a law 15 16 17 f that has appeared on behalf of that party, and includes support staff. irm 2 .11 etP : any party to this Action, including all ofits officers, directors, 18 ' 19 20 21 employees, consultants, retained experts, and Outside Counsel of Record (and their support staffs). .12 Producin~arty: a Party or Non-Party that produces Disclosure or 2 22 23 24 ', 25 I~' Discovery Material in this Action. 2 .13 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or 2 6 27 demonstrations, and organizing, storing, or retrieving data in any form or medium) 28 -6STIPULATED PR07'ECTIVE ORDER 1 and their employees and subcontractors. 2 .14 .Protected Material: any Disclosure or Discovery Material that is 2 3 4 designated as "CONFIDENTIAL." 5 2 .15 Receiving partX: a Party that receives Disclosure or Discovery 6 I Material from a Producing Party. 7 8 3 . 9 SCOPE The protections conferred. by this Stipulation and Order cover not only l0 Protected Material (as defined above), but also(1)any information copied or 11 12 extracted from Protected Material;(2) all copies, excerpts, summaries, or l3 compilations of Protected Material; and (3)any testimony, conversations, or 14 presentations by Parties or their Counsel that might reveal Protected Material. l5 ]6 CONFIDENTIAL Information may not be used or referenced outside of this 17 Action. Either party may petition the Court at the appropriate time to modify this 18 l9 Order so that CONFIDENTIAL Information may be used outside of this ACTION 20 based on a showing of good cause. 21 4 . DURATION 22 23 i This Stipulation and Order is entered into "postjudgment" as 24 Plaintiff/Judgment Creditor IROQUOIS MASTER FUND,LTD obtained a 25 judgment against Defendant/Judgment Debtor GLOBAL ePOINT,INC. This 2 6 27 protective order shall be effective upon entry of this order and apply to Discovery 28 -7STIPULATGD PROTECTING ORDER 1 ~ Material produced on and after such date and continue until such time that the 2 Court orders otherwise. 3 4 5 5 . DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Desi~n n~ Material for Protection. 6 ~ each Party or Non. -Party that designates information or items for protection under 7 8 ~ this Order must take care to limit any such designation to specific material that 9 qualifies under the appropriate standards. The Designating Party must designate for 10 ~ protection only those parts of material, documents, items or oral or written it ]2 communications that qualify so that otller portions ofthe material, documents, ]3 items or communications for which protection is not warranted are not swept 14 unjustifiably within the ambit of this Order. IS 16 17 Mass, indiscriminate or routinized designations are prohibited. Designations that are shown to be clearly unjustified or that have been made for an improper 18 purpose (e.g., to unnecessarily encumber the case development process or to 19 2 0 impose unnecessary expenses and burdens on other parties) may expose the 21 Designating Party to sanctions. 22 i 23 If it comes to a Designating Party's attention that information or items that it 24 designated for protection do not qualify for protection, that Designating Party must 25 promptly notify all other Parties that it is withdrawing the inapplicable designation. i 2 6 27 5.2 Manner and Timin ~of Designations. Except as otherwise provided in 28 -sSTIPUL,ATGD PROTEC'fIVC ORDER 1 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 2 stipulated. or ordered, Disclosure or Discovery Material that qualiftes for protection 3 4 under this Order must be clearly so designated before the material is disclosed or 5 produced. 6 Designation in conformity with this Order requires: 7 8 9 a. For information in documentary form (e.g., paper or electronic documents, but excluding transcripts of depositions or other pretrial or 10 trial proceedings), that the Producing Party affix at a minimum,the legend ]1 CONFIDENTIAL"(hereinafter "CONFIDENTIAL legend"), to each page that 12 " 13 contains protected material. If only a portion of the material on a page qualifies for 14 protection, the Producing Party also must clearly identify the protected portions) 15 e.g., by malting appropriate markings in the margins). 16 ( 17 A Party or Non-Party that makes original documents available far inspection 18 need not designate them for protection until after the inspecting Party has indicated 19 20 which documents it would like copied and produced. During the inspection and 21 before the designation, all of the material made available for inspection shall be 22 23 deemed "CONFIDENTIAL." After the inspecting Party has identified the 24 documents it wants copied and produced, the Producing Party must determine 25 which documents, or portions thereof, qualify for protection under this Order. 26 27 Then, before producing the specified documents, the Producing Party must affix 28 -9S"fIPULATED PI20'i'ECTIVC ORDER 1 the "CONFIDENTIAL legend" to each page that contains Protected Material. If 2 only a portion of the material on a page qualifies for protection., the Producing 3 4 Party also must clearly identify the protected portions)(e.g., by making 5 appropriate markings in the margins). 6 b. For testimony given in depositions that the Designating Party 7 8 identifies the Disclosure or Discovery Material on the record, before the close of 9 the deposition all protected testimony. 10 11 c. For information produced in some form other than documentary and l2 f any other tangible items, that the Producing Party affix in a prominent place on or 13 the exterior ofthe container or containers in which the infot~nation is stored the 14 legend "CONFIDENTIAL." If only a portion or portions of the information 15 l6 warrants protection, the Producing Party, to the extent practicable, shall identify 17 the protected portion(s). 18 I!~ 19 'I~ 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 20 failure to designate qualified information or items does not, standing alone, waive 21 the Designating Patty's right to secure protection under this Order for such 22 23 material. Upon timely correction of a designation, the Receiving Party must make 24 reasonable efforts to assure that the material is treated in accordance with the 25 provisions of this Order. Nothing in this protective order shall be construed as 2 6 27 allowing a party to designate as .Protected Material documents or information 28 -1 oS'PIPULA1'ED PROTECTIVE ORDER 1 ~ produced prior to entry of this protective order absent an additional order ofthe 2 Court. 3 4 ', 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 5 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 6 designation of confidentiality at any time that is consistent with the Court's 7 8 Scheduling Order. 9 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 10 resolution process under Local Rule 37-1 et seq. 11 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 12 13 joint stipulation pursuant to Local Rule 37-2. 14 6.4 The burden of persuasion in any such challenge proceeding shall be on IS 16 the Designating Party. Frivolous challenges, and those made for an improper 17 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 18 19 parties) may expose the Challenging Party to sanctions. Unless the Designating 20 Party has waived or withdrawn the confidentiality designation, all parties shall 21 continue to afford the material in question the level of protection to which it is 2 2 23 entitled under the Producing Party's designation until the Court rules on the 24 challenge. 25 7 . ACCESS TO AND USE OF PROTECTED MATERIAL 2 6 27 7.1 Basic Principles. A Receiving Party may use Protected Material that is 28 STIPULATED PROTECTIVE ORDER i disclosed or produced by another Party or by a Non-Party in connection with this 2 Action only for prosecuting, defending or attempting to settle this Action. Such 3 4 Protected Material may be disclosed only to the categories of persons and under 5 the conditions described in this Order. When the Action has been terminated, a 6 Receiving Party must comply with the provisions of section 13 below(FINAL 7 8 9 DISPOSITION). Protected Material must be stored and maintained by a Receiving Party at a 10 t1 12 13 location and in a secure manner that ensures that access is limited to the persons authorized under this Order. 7 Disclosure of"CONFIDENTIAL" Information or Items. Unless .2 14 15 otherwise ordered by the court or permitted in writing by the Designating Party, a 16 Receiving Party may disclose any information or item designated 17 " CONFIDENTIAL" only to: 18 19 a. the Receiving Party's Outside Counsel of Record in this Action, as 20 well as employees of said Outside Counsel of Record to whom it is reasonably 21 necessary to disclose the information for this Action; 22 23 b. the officers, directors, and employees (including House Counsel) of 24 ', the Receiving Party to whom disclosure is reasonably necessary for this Action; 25 c. Experts (as defined in this Order) of the Receiving Party to whom 2 6 27 disclosure is reasonably necessary for this Action and who have signed the 28 -12S"fll'ULA'fED PROTECTIVE ORDER 1 "Acknowledgment and Agreement to Be Bound"(Exhibit A); 2 d. the court and its personnel; 3 4 e. court reporters and their staff; 5 f professional jury or trial consultants, mock jurors, and Professional . 6 ~ Vendors to whom disclosure is reasonably necessary for this Action and who have 7 8 signed the "Acknowledgment and Agreement to Be Bound"(Exhibit A); 9 g. the author or recipient of a document containing the information or a 10 i, custodian or other person who otherwise possessed or knew the information; 11 h. during their depositions, witnesses, and attorneys for witnesses, in the 12 1 3 ' Action to whom disclosure is reasonably necessary provided:(1)the deposing 14 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2} 15 16 they will not be permitted to keep any confidential information unless they sign the 17 " Acknowledgment and Agreement to Be Bound"(Exhibit A), unless otherwise 18 agreed by the Designating Party or ordered by the court. Pages of transcribed 19 2 0 deposition testimony or exhibits to depositions that reveal Protected Material may 21 be separately bound by the court reporter and may not be disclosed to anyone 22 23 except as permitted under this Stipulated Protective Order; and i. any mediator or settlement officer, and their supporting personnel, 24 25 mutually agreed upon by any of the parties engaged in settlement discussions. 2 6 27 8 . PROT~CT~D MATERIAL SUBPOENAED OR ORDERED 28 -13STIPULATF.D PROTECTING ORD@R 1 PRODUCED IN OTHER LITIGATION 2 If a Party is served with a subpoena or a court order issued in other litigation 3 4 ~ that compels disclosure of any information or items designated in this Action as 5 ~ "CONFIDENTIAL," that Party must: 6 a. promptly notify in writing the Designating Party. Such notification 7 8 ►!. shall include a copy of the subpoena or court order; b. promptly notify in writing the party who caused the subpoena or 10 >> order to issue in the other litigation that some or all of the material covered by the 12 subpoena or order is subject to this Protective Order. Such notification shall 13 include a copy of this Stipulated Protective Order; and 14 l5 16 c. cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material inay be affected. 17 If the Designating Party timely seeks a protective order, the Party served with 18 19 the subpoena or court order shall not produce any information designated in this 20 action as "CONFIDENTIAL" before a determination by the court from which the 21 subpoena or order issued, unless the Party has obtained the Designating Party's 22 23 permission. The Designating Party shall bear the burden and expense of seeking 24 protection in that court of its confidential material and nothing in these provisions 25 should be construed as authorizing or encouraging a Receiving Party in this Action 26 27 to disobey a lawful directive from another court. 28 -14STIPULATED PROTECTIVE ORDF,R l 9. ANON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 4 5 a. The terms of this Order are applicable to information produced by a Non-Party in this Action and designated as "CONFIDENTIAL." Such information 6 produced by Non-Parties in connection with this litigation is protected by the 7 8 remedies and relief provided by this Order. Nothing in these provisions should be 9 construed as prohibiting allon-Party from seeking additional protections. 10 b. In the event that a Party is required, by a valid discovery request, to 11 12 produce allon-Party's confdential information in its possession, and the Party is 13 subject to an agreement with the Non-Party not to produce the Non-Party's 14 confidential information, then the Party shall: 15 16 17 1. promptly notify in writing the Requesting Party and the Non-.Party that some or all of the information requested is subject to a 18 confidentiality agreement with allon-Party; 19 20 21 2 promptly provide the Non-Party with a copy ofthe . Stipulated Protective Order in this Action, the relevant discovery request(s), and a 22 23 24 25 reasonably specific description of the information requested; and 3. make the information requested available for inspection by the Non-Party, if requested. 2 6 27 c. If the Non-Party fails to seek a protective order from this court within 28 -]5S'I'IPULATED PROTECTIVE ORDER 1 ~ 14 days of receiving the notice and accompanying information, the Receiving 2 ~ Party may produce the Non-Party's confidential information responsive to the 3 4 discovery request. If the Non-Party timely seeks a protective order, the Receiving 5 ~ Party shall not produce any information in its possession or control that is subject 6 to the confidentiality agreement with the Non-Party before a determination by the 7 8 ~ court. Absent a court order to the contrary, the Non-Party shall bear the burden and 9 expense of seeking protection in this court of its Protected Material. 10 '~ 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 12 I a Receiving Party learns that, by inadvertence or otherwise, it has disclosed f 13 ' Protected Material to any person or in any circumstance not authorized under this 14 IS Stipulated Protective Order, the Receiving Party must immediately (a) notify in 16 writing the Designating Party of the unauthorized disclosures, (b) use its best 17 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 18 19 person or persons to whom unauthorized disclosures were made of all the terms of 2 0 this Order, and (d) request such persons) to execute the "Acknowledgment and 21 Agreement to Be Bound" that is attached hereto as Exhibit A. 22 23 24 25 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL When a Producing Party gives notice to Receiving Parties that certain 2 6 27 ►~ -16STIPULATED PRO"fECTIVG ORDER 1 inadvertently produced material is subject to a claim of privilege or other 2 protection, the obligations of the Receiving Parties are those set forth in Federal 3 4 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 5 whatever procedure may be established in an e-discovery order that provides for 6 production without prior privilege review. Pursuant to Federal Rule of Evidence 7 8 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 9 of a communication or information covered by the attorney-client privilege or 10 work product protection, the parties may incorporate their agreement in the 11 12 stipulated protective order submitted to the court. 13 12. MISC~LLAN~OUS 14 12.1 Right to Further Relief. Nothing in this Order abridges the right of 15 16 Any person to seek its modification by the Court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 19 Protective Order, no Party waives any right it otherwise would have to object to 20 disclosing or producing any information or item on any ground not addressed in 21 this Stipulated Protective Order. Similarly, no Party waives any right to object on 22 23 24 25 any ground to use in evidence of any of the material covered by this Protective Order. 12.3 Filing Protected Material. A Party that seeks to file under seal any 2 6 27 Protected Material must comply with Local. Civil Rule 79-5. Protected Material 28 -t7STIPULATF.,D PIiOTGCTIVE ORDER 1 may only be filed under seal pursuant to a court order authorizing the sealing of the 2 specific Protected Material. at issue. If a Party's request to file Protected Material 3 4 under seal is denied by the court, then the Receiving Party may file the information 5 in the public record unless otherwise instructed by the court. 6 / // 7 8 13. 9 After the final disposition. of this Action, as defined in paragraph 4, within 60 FINAL DISPOSITION 10 days of a written request by the Designating Party, each Receiving Party must 11 2 ] return all Protected Material to the Producing Party or destroy such material. As 13 used in this subdivision,"all Protected Material" includes all copies, abstracts, 14 compilations, summaries, and any other format reproducing or capturing any of the 15 16 Protected Material. Whether the Protected Material is returned or destroyed, the 17 Receiving Party must submit a written certification to the Producing Party (and, if 18 not the same person or entity, to the Designating Party) by the 60 day deadline that ~9 I 1) 20 ( identifies (by category, where appropriate) all the Protected Material that was 21 returned or destroyed and (2)affirms that the Receiving Party has not retained any 22 23 copies, abstracts, compilations, summaries or any other format reproducing or 24 capturing any ofthe Protected Material. Notwithstanding this provision, Counsel 25 are entitled to retain an archival copy of all pleadings, motion papers, trial, 2 6 27 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 28 -isSTIPULATCD PROTECTIVE ORDER 1 ~ and trial exhibits, expert reports, attorney work product, and consultant and expert 2 work product, even if such materials contain Protected Material. Any such archival 3 4 '~ copies that contain or constitute Protected Material remain subject to this 5 Protective Order as set forth in Section 4(DURATION). 6 14. VIOLATION 7 8 9 Any violation of this Order may be punished by appropriate measures including, without limitation, contempt proceedings and/or monetary sanctions. 10 IT IS SO STIPULATED,THROUGH COUNSEL OF RECORD. 11 DONBOLI LAW GROUP, APC 12 13 14 ~~~~~~~ DATED: 12.23.17 Jo H. Donboli Attorney for Judgment Debtor: Global ePoint, Inc. 15 16 MINTZ LEVIN 17 l8 DATED: iz, z7 ~~ 19 2 0 21 I , __ }-- __.~..~ _ -- " Joseph Dunn Attorney for Judgment Creditor: Iroquois Master Fund, Ltd. 22 FOR GOOD CAUSE SHOWN,IT IS SO ORDERED. 23 DATED: , i~ `O~ 24 25 2 6 27 ~ ~~ ~~-~ ? HON. SUZ.~I NE H. SEGA~ United States Magistrate Judge 28 - l 9STIPULATED PR07'ECTfVE ORDER 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 IROQUOIS MASTER FUND,LTD., Plaintiff and Judgment Creditor, 13 14 15 CASE NO. 2:08-cv-07761 UA(SSx) STIPULATED PROTECTIVE ORDER vs. Magistrate Judge: Hon. Suzanne H. Segal GLOBAL ePOINT,Inc. 16 Defendants. 17 18 19 20 T ~TTTTT TT 21 22 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 23 I~ 24 [print or type full name], of 25 [print or type full address], declare under penalty of perjury 26 ~ that I have read in its entirety and understand the Stipulated Protective Order that 27 28 -20STIPULATED PROTECTIVE ORDER 1 was issued by the United States District Court for the Central District of California 2 on [date] in the case ofIroquois Master Fund, Ltd v. Global ePoint, Inc, Case No. 3 4 ~, 2:08-cv-07761 UA (SSx). I agree to comply with and to be bound by all the terms 5 of this Stipulated Protective Order and I understand and acknowledge that failure 6 to so comply could expose me to sanctions and punishment in the nature of 7 8 I, contempt. I solemnly promise that I will not disclose in any manner any 9 information or item that is subject to this Stipulated Protective Order to any person t0 t~ or entity except in strict co►npliance with the provisions of this Order.Ifurther l2 agree to submit to the jurisdiction of the United. States District Court for the 13 Central District of California for enforcing the terms of this Stipulated Protective 14 t5 Order, even if such enforcement proceedings occur after termination of this action. [print or type full name] of 16 I hereby appoint 17 [print or type full address and 18 19 20 telephone number] as my California agent for service of process in connection with this action or any proceedings related to enforcement of this Stipulated Protective 21 ~ ~ Order. 22 23 Date: 24 City and State where sworn and signed: 25 Printed name: 26 27 Signature: 28 -2]STIPULATED PROTECTIVC ORDGR

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