United States of America v. The Zaken Corp et al

Filing 44

PROTECTIVE ORDER by Magistrate Judge Margaret A. Nagle re Joint APPLICATION for Protective Order for Production of Discovery Material 42 (ec)

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UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA,

)
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Plaintiff,
)
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v.
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THE ZAKEN CORP., a California
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corporation, also d/b/a The Zaken
Corporation, QuickSell, and QuikSell; )
and
)
TIRAN ZAKEN, individually and as )
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an officer of The Zaken Corp.,
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Defendants.
)
)
)

Case No: CV-12-09631 DDP(MANx)
PROTECTIVE ORDER ENTERED
PURSUANT TO THE PARTIES’
STIPULATION

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Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and based on
the parties’ Stipulated Protective Order Governing the Production of Discovery
Material (“Stipulation”) filed on August 1, 2013, the terms of the protective order
to which the parties have agreed are adopted as a protective order of this Court
(which generally shall govern the pretrial phase of this action) except to the extent,
as set forth below, that those terms have been substantively modified by the
Court’s amendment of paragraphs 2, 7, 23, and 24 of the Stipulation.

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The parties are expressly cautioned that the designation of any information,
document, or thing as Confidential, or other designation(s) used by the parties,
does not, in and of itself, create any entitlement to file such information, document,
or thing, in whole or in part, under seal. Accordingly, reference to this Protective
Order or to the parties’ designation of any information, document, or thing as
Confidential, or other designation(s) used by the parties, is wholly insufficient to
warrant a filing under seal.
There is a strong presumption that the public has a right of access to judicial
proceedings and records in civil cases.

In connection with non-dispositive

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motions, good cause must be shown to support a filing under seal. The parties’

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mere designation of any information, document, or thing as Confidential, or other

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designation(s) used by parties, does not -- without the submission of competent

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evidence, in the form of a declaration or declarations, establishing that the

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material sought to be filed under seal qualifies as confidential, privileged, or

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otherwise protectable -- constitute good cause.

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Further, if sealing is requested in connection with a dispositive motion or

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trial, then compelling reasons, as opposed to good cause, for the sealing must be

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shown, and the relief sought shall be narrowly tailored to serve the specific interest

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to be protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th

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Cir. 2010). For each item or type of information, document, or thing sought to be

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filed or introduced under seal in connection with a dispositive motion or trial, the

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party seeking protection must articulate compelling reasons, supported by specific

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facts and legal justification, for the requested sealing order. Again, competent

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evidence supporting the application to file documents under seal must be

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provided by declaration.

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Any document that is not confidential, privileged, or otherwise protectable

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in its entirety will not be filed under seal if the confidential portions can be

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redacted.

If documents can be redacted, then a redacted version for public

viewing, omitting only the confidential, privileged, or otherwise protectable
portions of the document, shall be filed.

Any application that seeks to file

documents under seal in their entirety should include an explanation of why
redaction is not feasible.
Notwithstanding any other provision of this Protective Order, in the event
that this case proceeds to trial, all information, documents, and things discussed or
introduced into evidence at trial will become public and available to all members
of the public, including the press, unless sufficient cause is shown in advance of
trial to proceed otherwise.

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TERMS OF PROTECTIVE ORDER

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Materials Covered

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This Protective Order, and the confidentiality provisions contained herein,

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shall where applicable, apply to all documents, information, and other materials

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disclosed and produced by Plaintiff, Defendants, and any third-party that produces

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information in response to a subpoena (the “Disclosing Party”) in the entitled

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action, and all oral depositions. Such documents, information, and other materials

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shall be referred to hereinafter as “Litigation Material.”

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Definition and Use of “Confidential Consumer Information”
1.

“Confidential

Consumer

Information”

shall

mean

identifying

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information relating to any individual consumer, including the consumer’s

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financial or credit information, postal address, email address, telephone number,

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social security number, driver’s license number or other state identification

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number.

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2.

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protected.

The parties agree that Confidential Consumer Information should be
Confidential Consumer Information includes personally-identifying

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information about Defendants’ customers and records and information compiled by
the Federal Trade Commission for law-enforcement purposes, including consumer
complaints, which is nonpublic information for many purposes.

16 C.F.R.

§ 4.10(a)(5). The United States has represented to the Court that almost all of the
complaints that it receives regarding the sale of business opportunities are received
through or are stored in the Consumer Sentinel database. This database is part of
the Consumer Information System (“CIS”), maintained and operated by the
Federal Trade Commission. The CIS is a designated “system of records” subject to
protection under the Privacy Act, 5 U.S.C. § 552a, because consumer complaints

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and other submissions include confidential personally-identifying information

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about individuals. Notice of Revised System Notices, 73 Fed. Reg. at 33621

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(Consumer Information System).

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3.

The United States has asserted that federal agencies cannot

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disclose records contained in a “system of records” absent written permission from

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the individual to whom the record pertains, unless one of twelve specific statutory

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exceptions applies. 5 U.S.C. § 552a(b). One exception that allows an agency to

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disclose records contained in a “system of records” is “the order of a court of

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competent jurisdiction.” 5 U.S.C. § 552a(b)(11). Accordingly, an appropriate

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order from this Court would authorize the United States to disclose record

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information from the Consumer Information System to the defendants in discovery.

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4.

Confidential Consumer Information shall be treated as such without

any written designation or identification.
5.

Plaintiff and Defendants may use Confidential Consumer Information

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received in this litigation only for purposes of this litigation. No party or person

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receiving Confidential Consumer Information shall use such material or the

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contents thereof for any other business, commercial, governmental, or competitive

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purposes. The parties acknowledge, however, that Plaintiff may use such material

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for law-enforcement purposes, unless such use would violate the constitutional or
statutory rights of the producing parties or of individuals whose personallyidentifying information is disclosed, or depart from “proper standards in the
administration of justice.” United States v. Stein, 2008 U.S. Dist. LEXIS 74030, at
*10 (S.D.N.Y. Sept. 10, 2008); see United States v. Stringer, 535 F.3d 929 (9th Cir.
2008); SEC v. Dresser Industries, Inc., 628 F.2d 1368 (D.C. Cir. 1980).
6.

Any party may publicly file a document or a deposition transcript

containing Confidential Consumer Information, so long as all Confidential
Consumer Information is redacted in the publicly-filed version of the document or

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transcript. Alternatively, any party may apply for leave to file under seal an

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unredacted copy of a document or deposition transcript containing Confidential

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Consumer Information. The parties must comply with Local Rule 79-5.1 when

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seeking to file documents under seal.

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7.

Prior to any evidentiary court proceedings in this matter, the parties

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will meet and confer in good faith to put into place a procedure for identification

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and use of Confidential Consumer Information during trial or other evidentiary

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court proceedings. Prior to any such proceeding(s), the parties will seek to obtain

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an appropriate Court order regarding the use and protection of Confidential

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Consumer Information.

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8.

The provisions in paragraphs 15 through 30 of this Protective Order

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shall apply equally to Confidential Consumer Information as to information

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designated Confidential Litigation Material.

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Definition of “Confidential” Litigation Material
9.

“Confidential” Litigation Material shall include Litigation Material so

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designated by counsel of record who reasonably and in good faith believes such

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Litigation Material is of the type protectable under Fed. R. Civ. P. 26(c)(1)(G) or

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which satisfies the following definition.

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“Confidential” Litigation Material is

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information that contains, reflects or reveals: (1) trade secret information (which is
a formula, pattern, or device for compilation of information which is used in one's
business, and which gives the business an opportunity to obtain an advantage over
competitors who do not know or use the trade secret information); (2) proprietary
information such as research and development information, or commercially or
competitively sensitive information; and/or (3) privileged or confidential
commercial or financial information. By designating information as Confidential
under this Protective Order, the attorney for a Designating Party (or the
Designating Party personally, if unrepresented) certifies to the Court within the

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meaning of Fed. R. Civ. P. 26(g)(1) that there is a good faith basis for the

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designation, both in law and fact and based upon careful determination. Material is

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not to be designated Confidential Litigation Material as a matter of course.

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10.

Litigation Material will not be deemed Confidential and protected,

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and the parties shall use reasonable efforts to ensure that Litigation Material is not

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designated as such, if the content or substance of such Litigation Material is at the

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time of production or disclosure, or subsequently becomes, through no wrongful

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act or failure to act on the part of the receiving party, generally available to the

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public through publication or otherwise.

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Method of Designation
11.

The Disclosing Party may designate as Confidential all or any portion

of any Litigation Material as follows:
a.

Litigation Material produced in paper form may be designated

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as Confidential by prominently stamping or writing the legend “Confidential” on

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each page of the Litigation Material containing Confidential information at or

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before production.

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segregable on a given page, Confidential information may be identified by

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stamping “Confidential” adjacent to the Confidential passages.

Where the Confidential Litigation Material is reasonably

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b.

designated as Confidential by prominently marking the legend “Confidential” on
each page of the Litigation Material containing Confidential information at or
before production.

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Where the Confidential Litigation Material is reasonably

segregable on a given page, Confidential information may be identified by
stamping “Confidential” adjacent to the Confidential passages.

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Litigation Material produced in electronic TIFF format may be

c.

Litigation Material produced in native format (i.e. Word,

Excel), may be designated as Confidential by including the designation of
Confidential in the file name of such Litigation Material and/or by preserving its

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confidentiality in accordance with any Electronically Stored Information

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Agreement the parties may enter.

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Material by copying or printing shall be designated by the person printing the

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Litigation Material as Confidential by prominently stamping or writing the legend

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“Confidential” on each page of the Litigation Material containing Confidential

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information.

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d.

Any production of Confidential Litigation

Confidential Litigation Material produced in native format shall

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not be distributed electronically without maintaining the designation of

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Confidential in the file name of such Litigation Material and/or, if encryption was

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used, the encryption of that Litigation Material, and the encryption key shall not be

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shared with any person that is not entitled to gain access to that Litigation Material

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under the terms of this Protective Order.

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e.

Other discovery responses (such as responses to interrogatories

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and requests for admission) that it served in paper, PDF, or TIFF format, and that

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the Designating Party in good faith believes constitute or include Confidential

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Litigation Material, shall be designated on each confidential passage with the

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legend “Confidential.”

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f.

Deposition testimony may be designated as Confidential by

either of the following means: (i) by stating orally on the record that an answer to
a question is Confidential prior to or immediately after the witness’s answering the
question; or (ii) by sending written notice designating specific pages and lines of
the deposition transcript as Confidential within ten (10) business days of the date
on which counsel receives the transcript from the court reporter. By stating orally
that a portion of a deposition is Confidential, a party does not thereby waive its
right to designate additional portions as such within the ten (10) business day
period. All information disclosed during a deposition shall be deemed to have

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been designated Confidential until ten (10) business days after the transcript is

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received from the court reporter, whether or not portions of the transcript have

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been previously so designated. Following the expiration of the ten (10) business

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day period, only those portions of the deposition testimony specifically designated

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as Confidential shall be treated as such.

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g.

Upon request by a Recipient, a Producing Party shall, in good

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faith, review any Litigation Material it has designated as “Confidential” to

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determine whether any part of the confidentiality designations may be removed.

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The Producing Party shall notify the Recipient within ten (10) business days

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whether, based on that good-faith review, the Producing Party agrees that any part

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of the confidentiality designations can be removed. Any disputes concerning such

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a request shall be resolved as provided for in paragraph 13 below; provided that all

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parties hereby acknowledge in advance that the Confidential Designation is

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intended only to cover those parts of Litigation Material that require such

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protection.

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12.

Inadvertent production of Litigation Material without any designation

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shall not constitute a waiver of the right to designate information as Confidential.

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If Litigation Material is inadvertently produced without the appropriate

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designation, any party may nevertheless assert that the Litigation Material is
Confidential, and the parties shall thereafter treat it as such. The Disclosing Party
shall reproduce the Litigation Material with the appropriate designation, in
accordance with paragraph 10 above, within ten (10) business days of the new
assertion of confidentiality.

After being notified, a party must promptly return,

sequester, or destroy the Confidential information and any copies it has, must take
reasonable steps to retrieve the information if the party disclosed it before being
notified, and must not use or disclose the Confidential information, except to
challenge the confidentiality designation as provided in paragraph 13.
13.

Inadvertent production of any Litigation Material by any party that a

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Disclosing Party later claims should have been withheld on grounds of a privilege,

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including the work product doctrine or attorney-client privilege, will be handled in

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accordance with Fed. R. Civ. P. 26(b)(5)(B).

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Objections to Confidential Treatment
14.

The failure to challenge the propriety of a designation of Litigation

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Material as Confidential at the time made does not preclude a subsequent challenge

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thereto. If, at any time, a party believes that all or part of any Litigation Material

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designated Confidential by the Disclosing Party does not contain Confidential

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material, the parties shall engaged in the following procedures:

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a.

Any party (the “Requesting Party”) may at any time request the

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Designating Party to release any Confidential designations made under this

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Protective Order. Pursuant to Local Rule 37-1 (C.D. Cal. 2010), the request shall

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(1) be in writing; (2) identify each issue and/or Confidential designation in dispute;

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(3) state briefly with respect to each such issue or Confidential designation the

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Requesting Party’s position (and provide any legal authority that the Requesting

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Party believes is dispositive of the dispute as to that issue or Confidential

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designation); and (4) specify the terms of the discovery order to be sought. With

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respect to requirement (3), it shall be sufficient for the Requesting Party to state
that it puts the Designating Party to its burden of persuasion.
b.

Pursuant to Local Rule 37-1, unless relieved by written order of

the Court upon good cause shown, counsel for the Designating Party shall confer
with counsel for the Requesting Party within ten (10) days of the Requesting
Party’s written request.

Because the Designating Party bears the burden of

persuasion, it shall be the moving party.
c.

If the parties cannot reach agreement, the Designating Party

must move the Court to issue a protective order retaining its Consumer

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Confidential designations (or seeking other appropriate relief) if it wishes to retain

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those designations.

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i.

The Requesting and Designating Parties shall cooperate in

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formulating and preparing the joint stipulation pursuant to

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Local Rule 37-2.2, and shall comply with the remaining

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requirements of Local Rules 37-2, 37-3, and 37-4.

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ii.

shall, within ten (10) days of the conference, serve its portion of

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the Local Rule 37-2.2 joint stipulation and accompanying

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declarations and exhibits upon counsel for the Requesting Party,

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in accord with the requirements of Local Rule 37-2.2. If the

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Designating Party does not do so, it shall be deemed to have

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abandoned the challenged Consumer Confidential Information

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designations, and the designated material shall no longer be

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protected under this Protective Order.

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Unless the parties agree on a longer time, the Designating Party

iii.

Unless the parties agree on a longer time, counsel for the
Requesting Party shall serve on counsel for the Designating

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Party the Requesting Party’s portion of the stipulation, together

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with accompanying declarations and exhibits, in accord with

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Local Rule 37-2.2, within seven (7) days of receipt of the

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Designating Party’s papers. If counsel for the Requesting Party

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does not do so, the Requesting Party shall be deemed to have

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abandoned its challenge, and the Designating Party shall not be

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required to take further action to retain the challenged

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Consumer Confidential designations.

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iv.

Unless the parties agree on a longer time, counsel for the

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Designating Party shall add the Requesting Party’s papers to the

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stipulation and provide the stipulation to counsel for the

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Requesting Party for signature in accord with Local Rule 37-

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2.2, within five (5) days of receipt of the Requesting Party’s

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papers. If counsel for the Designating Party does not do so, the

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Designating Party shall be deemed to have abandoned the

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challenged Consumer Confidential Information designations,

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and the designated material shall no longer be protected under
this Protective Order.

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v.

Unless the parties agree on a longer time, counsel for the

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Requesting Party shall sign (electronically or otherwise) and

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return the stipulation to counsel for the Designating Party by

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the end of the next business day in accord with Local Rule 37-

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2.2. If counsel for the Requesting Party does not do so, the

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Requesting Party shall be deemed to have abandoned its

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challenge and the Designating Party shall not be required to

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take further action to retain the challenged Consumer

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Confidential designations.

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vi.

Unless the parties agree on a longer time, the Designating Party

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shall file its motion for protective order (or seeking other

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appropriate relief) within seven (7) days after receipt of the

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signed stipulation from counsel for the Requesting Party. If the

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Designating Party does not do so, it shall be deemed to have

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abandoned the challenged Consumer Confidential Information

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designations, and the designated material shall no longer be

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protected under this Protective Order.

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vii.

The Designating Party shall bear the burden of persuasion on its

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motion for a protective order retaining its Consumer

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Confidential designations (or seeking other appropriate relief).

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viii. With its motion, the Designating Party shall submit to the Court

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for filing under seal the information or document whose

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treatment is disputed (or, if the material is voluminous, an

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appropriate subset). In accord with the requirements of Local

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Rule 79-5.1, the Designating Party shall present a written
application and a proposed order to the judge along with the
information or document submitted for filing under seal. The
Designating Party’s proposed order shall address both its
underlying motion for protective order (or other appropriate
relief) and its application for under-seal filing (and in accord
with Local rule 79-5.1, the proposed order shall also, if

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appropriate, address whether the application and proposed order

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themselves should be sealed).

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ix.

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The terms of this Protective Order shall continue to apply to the

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information or documents that are the subject of the motion

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until the Court rules.

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Use and Treatment of Confidential Material
15.

Any person responsible for making copies of Confidential Litigation

Material must ensure that the copies adequately reflect the Confidential
designation thereof.
16.

Litigation Material designated as Confidential and Confidential

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Consumer Information, including any copies, notes, abstracts, or summaries

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thereof, shall be maintained in confidence by the Recipient, and shall not be

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disclosed to any person except:

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a.

the Court; all Court personnel; any discovery referee; or any

settlement mediator;
b.

court reporters or videographers who record deposition or other

testimony in this case;

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c.

outside and inside counsel to the parties, and their staff;

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d.

an individual party, or if a government or corporate entity, only

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those directors, officers, employees who require the Confidential Consumer

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Information and Litigation Material to perform his or her responsibilities in

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connection with this litigation, but only to the extent required to perform his or her

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responsibilities in connection with this litigation;

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e.

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assist counsel;

experts or consultants retained by the parties or their counsel to

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f.

Consumer and Litigation Material, or any person who would have had access to
the Confidential Consumer and Litigation Material by virtue of his/her
employment by the party producing the Confidential Consumer and Litigation
Material, as well as deposition and trial witnesses presently employed by the party
producing the Confidential Consumer and Litigation Material;

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the author, addressees, and recipients of the Confidential

g.

any other person upon the written agreement of the party who

produced or disclosed the Confidential Consumer and Litigation Material (which
written agreement may be recorded on a deposition or other transcript), or pursuant

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to court order;

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h.

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outside copy and computer services personnel for purposes of

copying, imaging, or indexing Litigation Material.
17.

All persons authorized by this Protective Order to receive

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Confidential Consumer and Litigation Material shall not disclose the Confidential

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information and shall maintain such information as confidential in accordance with

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this Protective Order. Confidential Consumer and Litigation Material shall be used

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only for the prosecution or defense of this litigation. No party or person receiving

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Confidential Consumer and Litigation Material shall use such material or the

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contents thereof for any other business, commercial, or competitive purposes. The

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parties acknowledge, however, that Plaintiff may use such material for law-

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enforcement purposes, unless such use would violate the producing parties’

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constitutional rights, or depart from “proper standards in the administration of

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justice.” United States v. Stein, 2008 U.S. Dist. LEXIS 74030, at *10 (S.D.N.Y.

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Sept. 10, 2008); see United States v. Stringer, 535 F.3d 929 (9th Cir. 2008); SEC v.

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Dresser Industries, Inc., 628 F.2d 1368 (D.C. Cir. 1980).

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18.

Prior to being shown any Confidential Consumer or Litigation

Material, any person listed under paragraph 15(d) or 15(e) shall agree to be bound

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by the terms of this Protective Order by signing the agreement attached as Exhibit
A.
19.

Each person given access to information designated as or derived

from Confidential Information under this Protective Order shall be advised that the
material or information is being disclosed pursuant and subject to the terms of this
Protective Order and may not be disclosed other than pursuant to its terms.
20.

In the event any additional party joins or is joined in this action, the

newly joined party shall not have access to Confidential Consumer and Litigation
Material until the newly joined party, by its counsel, has executed its agreement to

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be bound fully by this Protective Order by executing and delivering to the parties

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hereto an agreement to be bound by its terms.

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Unauthorized Disclosure
21.

In the event that Confidential Consumer and Litigation Material is

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disclosed to someone not authorized to receive such information under this

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Protective Order, or if any person so authorized breaches any of his or her

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obligations under this Protective Order, counsel of record for the party involved

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shall immediately give notice of such unauthorized disclosure or breach, including

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a full description of all pertinent facts, to the Court and to all counsel of record.

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Without prejudice to other rights and remedies of the designating party, counsel for

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the party making the disclosure shall make every reasonable effort to prevent

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further disclosure by it or by the person who was the recipient of such information.

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Use in Court

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22.

Except as provided in this paragraph, nothing in this Protective Order

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shall be construed to restrict or limit the ability of any party to use any information

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designated as or derived from Confidential Consumer and Litigation Material

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under this Protective Order in any filing or submission to this Court. Any person

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may publicly file a document or a deposition transcript marked or identified as

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Confidential Consumer and Litigation Material, so long as all Confidential portions
are redacted in the publicly-filed version of the document or transcript.
Alternatively, any party may apply for leave to file under seal an unredacted copy
of a document or deposition transcript containing Confidential Consumer or
Litigation Information. The parties must comply with Local Rule 79-5.1 when
seeking to file documents under seal.
23.

Prior to any evidentiary court proceedings in this matter, the parties

will meet and confer in good faith to put into place a procedure for identification
and use of Confidential Consumer and Litigation Material during trial or other

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evidentiary court proceedings. Prior to any such proceeding(s), the parties will

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seek to obtain an appropriate Court order regarding the use and protection of

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Confidential Consumer and Litigation Material.

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Subpoena or Public Access to Records Request by a Third Party
24.

If one of the parties in possession of Confidential Consumer and

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Litigation Material receives a subpoena or public access to records request (e.g.

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Freedom of Information Act, 5 U.S.C. § 552(b)(4)) from a non-party which seeks

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or compels the production or other disclosure of Confidential Consumer and

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Litigation Material, the recipient of the request shall immediately give written

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notice to counsel for the party who designated the Confidential Consumer and

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Litigation Material as Confidential, identifying the material sought and enclosing a

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copy of the subpoena or request. Where possible, at least ten (10) days’ notice

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before production or other disclosure shall be given. In no event shall production

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or disclosure be made before notice is given and received.

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Protective Order should be construed as authorizing a party in this action to

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disobey a lawful directive from another court.

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Nothing in this

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Conclusion of Litigation
25.

Within sixty (60) days of the conclusion of any litigation arising out

of the above-entitled action, including the exhaustion of all appeals and expiration
of the time for seeking any further review, counsel of record for the parties shall,
subject to applicable state and federal public records laws, either destroy all
Confidential Consumer and Litigation Material or return such Material to counsel
for the party who initially produced the Confidential Consumer and Litigation
Material (at the Disclosing Party’s option).

In the event that Confidential

Consumer and Litigation Material is mixed with non-confidential litigation

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material on a piece of electronic media, the Receiving Party may make a copy of

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the non-confidential litigation material and thereafter shall return the original

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electronic media to the Producing Party. Termination of the litigation does not

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relieve the parties or the individuals who signed Exhibit A from their obligations

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under the protective order. The parties may keep copies of Confidential Consumer

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and Litigation Material to the extent necessary and appropriate to enforce any

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order of the Court.

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Amendment of This Agreement
26.

The provisions of this Protective Order may be modified at any time

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by stipulation of the parties approved by Court order. In addition, a party may at

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any time apply to this Court for modification of this Protective Order pursuant to a

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motion brought in accordance with the rules of this Court. The parties consent to

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an expedited hearing upon any such application.

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27.

Nothing contained in this Protective Order shall be construed as a

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waiver by any party of its right to object on any other permissible grounds to any

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request for production of documents, nor as a waiver by any party of another

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party’s obligation to make proper responses to discovery requests. The entry of

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this Protective Order shall not be construed as an agreement by any party to

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produce any documents or to supply any information and shall not constitute an
admission that any such documents that may exist are relevant or material in any
way to the issues raised in the pending action or admissible in such action, nor as a
waiver of any privilege with respect thereto.
28.

This Protective Order shall be without prejudice to the right of the

parties to request additional protection under Fed. R. Civ. P. 26(c) for discovery
requests made by any party.
29.

Nothing in this Protective Order shall be deemed to preclude a party

from intentionally waiving any protection afforded to its Confidential Litigation

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Material under this Protective Order, nor shall it prevent any party from disclosing

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its own information to any person it deems appropriate without waiving its rights

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under this Protective Order.

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IT IS SO ORDERED.

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Dated: October 9, 2013

____________________________________

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MARGARET A. NAGLE
UNITED STATES MAGISTRATE JUDGE

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1

EXHIBIT A

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UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA,

)
)
)
Plaintiff,
)
)
v.
)
)
THE ZAKEN CORP., a California
)
corporation, also d/b/a The Zaken
Corporation, QuickSell, and QuikSell; )
)
and
)
TIRAN ZAKEN, individually and as )
)
an officer of The Zaken Corp.,
)
Defendants.
)

Case No: CV-12-09631 DDP(MANx)
ACKNOWLDGEMENT OF
PROTECTIVE ORDER AS TO
CONFIDENTIAL
INFORMATION

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I have read the Protective Order entered in the above-captioned case on
October 9, 2013, and I agree to be bound by the terms of that Protective Order.
Signature: _________________________________

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Print Name:________________________________

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Title: ____________________________________
Employed by:

_____________________________

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Representing: ______________________________
Address: __________________________________

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__________________________________________
Date: _______________________________ ______

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