Moofly Productions, LLC v. Sandra Favila et al

Filing 60

PROTECTIVE ORDER by Magistrate Judge Patrick J. Walsh re Stipulation for Protective Order, 58 ; See order for details. (jy)

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-’ 1 Timothy J. Toohey, Esq. SBN: 140117 TTooheympp1aw. corn 2 MORRISPOLICH &PURDY LLP 1055 West Seventh Street, 24th Floor 3 Los Angeles, California 90017 Telephone:(213) 891-9100 4 Facsimile: (213) 488-1178 Attorneys for Defendant and Counter-Claimant ESTATE OF RICHARD C. CORRALES and 6 Counter-Claimant MOTION GRAPHIX, INC. 5 K Ct,Lh, U U RICTCOU __ ’4AR 2 ( 7 (ADDITIONAL COUNSEL LISTED BELOW) MY , ’P "y 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA ’11 MOOFLY PRODUCTIONS, LLC, a California Limited Liability Company, 12 Plaintiff, 13 VS. 14 15 SANDRA FAVILA, an individual; et al., 16 / ESTATE OF RICHARD C. 1,8 CORRALES; et al., Counter-Claimants, 20 vs. 21 HELENA PASQUARIELLA; et al., 22 172 : Wx) Discovery Cut-Off: Sept. 8 2014 Pre-Trial Conference; Nov. 1 2014 Trial Date: Dec. 2 0l4 Complaint Filed: Jan. 24, 2013 Defendants. 17 19 Case No.: 2:13-ev-586/ / STIPULATED PROTEC Counter-Defendants. 23 24 25 26 2,7 28. I STIPULATED PROTECTIVE ORDER ER I James K. Cameron, Esq. SBN: 75997 jkcameron1awmajLcom 2 JAMES K. CAMERON & ASSOCIATES, A PC 17605T ana treet 3 Encino, California 91316 Telephone: ~818)380-6880 Facsimile: 818) 817-2390 . Attorneys for Defendants ESTATE OF RICHARD C. CORRALES and SANDRA FAVILA and 6 Counter-Claimants ESTATE OF RiCHARD C. CORRALES and MOTION GRAPHIX, INC. 7 Gary R. Wallace, Esq. SBN: 132214 8 LAW OFFICE OF GARY R. WALLACE 9 4551 Glencoe Avenue, Suite 300 Marina del Rey, California 90292 10 Telephone: (310) 775-8719 Facsimile: (310) 775-8775 11 Attorneys for Defendants ESTATE OF RICHARD C. 12 CORRALES and SANDRA FAVILA and Counter-Claimant ESTATE OF RICHARD C. CORRALES 13 5 14 15 16 17 In 19. 20 21 22 23 24 2 STIPULATED PROTECTIVE ORDER 1’ Pursuant to Rule 26: of the Federal Rulsof Civil Procedure and the Parties’ 2 Stipulation, the Court issues the following Protective Order: 3 1. DEFINITIONS. 4 1.1 Party: any party to this action, including any party’s officers, 5 directors. 6 staff). 7 retained experts, and outside counsel (and their support 1.2 Disclosure or Discovery Material: for purposes of this Order, .8 "Discovery Material" means all items or information, regardless of the medium or 9 manner generated, stored, or maintained (including, among other things, 10 testimony, transcripts, or tangible things) that are produced or generated in 11 disclosures or responses to discovery in this matter, e.g.., documents, electronically 12 stored information, testimony, discovery request, discovery response, motion, 13 filing With the Court, thing, or any portion thereof that qualifies to be designated 14 "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES 15 161, ONLY under the standards developed under Fed. R. Civ. P. 26(c). 1.3 Designations: Any confidential or proprietary information or 17 document or electronically stored information produced by any party or non-party 18 as part of discovery in this action may be designated by the producing party as 19 "CONFIDENTIAL." As a general guideline, and without limitation, a document 20 .: or electronically stored information may be designated "CONFIDENTIAL" when 21 it contains personal or business financial information, including but not limited to 22 customer information, business relations, or any other matter that would put the 23 producing party at a competitive disadvantage if the information became known to 24 third parties. Material may be designated as "HIGHLY CONFIDENTIAL25 ATTORNEYS’ EYES ONLY" information if it constitutes trade secret 26 information or other confidential research, product or service development, or 27 commercial information subject to protection under Fed. R. Civ. P. 26(c)(1)(G) 28 and the disclosure of such information other than provided for by this Order for 3 STIPULATED PROTECTIVE ORDER 1 "ATTORNEYS’ EYES ONLY" informationwould materially affect the business, 2 financial or commercial interests of the party producing, such as (by way of 3 example but not limitation) information regarding the finances of the producing 4 party or which any party is under a separate contractual obligation to maintain as .5 confidential. 6 1.4 Receiving Party: a Party that receives Disclosure or Discovery 7 Material from a Producing Party. 8 9 1.5 JI Discovery Material in this action. 10 11 Producing Party: a Party or non-party that produces Disclosure or 1.6 Designating Party: a Party or non-party that designates information or items that it produces in disclosures or in responses to discovery as 12 "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES 13 ONLY." 14 1.7 Protected Material: the information in a Disclosure or Discovery 15 Material that is designated as "CONFIDENTIAL" or "HIGHLY 16 CONFIDENTIAL-ATTORNEYS’ EYES ONLY." 17 1.8 Outside Counsel: attorneys and their support staff who are not 18 employees of a Party but who are retained to represent or advise a Party in this 19 action. 20 1.9 House Counsel: attorneys who are employees of a Party. 21 1.10 Counsel (without qualifier): Outside Counsel and House Counsel (as 22 well as their support staffs). .23 1.11 Expert: a person or business entity, including its employees and 24 subcontractors, with specialized knowledge or experience in a matter pertinent to 25 the litigation who has been retained by a Party or its counsel to serve as an expert 26 witness or as a consultant in this action, whether disclosed or undisclosed, and 27 who is not a current employee of a Party’s competitor and who, at the time of 28 retention, has no pending application or offer to become an employee of or 4 STIPULATED PROTECTIVE ORDER J, 2 consultant to a Party’s competitor. This definition includes a professional jury or trial consultant retained in connection with this litigation. 3 1.12 Professional Vendors: persons or entities that provide litigation 4 J support services (e.g., photocopying; videotaping; translating; preparing exhibits 5 or demonstrations:; organizing, storing, retrieving data in any form or medium.; etc.) and their employees and subcontractors. 6 7 2. SCOPE. 8 The protections conferred by this Stipulation and Order cover not only 9 Protected Material (as defined above), but also any information copied or 10 extracted therefrom, as well as all copies, excerpts, summaries, or compilations ii thereof, plus testimony, conversations, or presentations by parties, experts, or 12 counsel to or in court or in other settings that contain or would reveal Protected 13 Material. 14 3. DURATION. 15: Even after the termination of this litigation, the confidentiality obligations 16 imposed by this Order shall remain in effect until a Designating Party agrees 17 otherwise in writing or a court order otherwise directs. The Court’s jurisdiction to 18 enforce the terms of the Order shall continue after the final conclusion of all 19 aspects of the litigation. 20 4. DESIGNATING PROTECTED MATERIAL. 21 4.1 Exercise of Restraint and Care in Designating Material for 22 Protection. To the extent reasonably possible, each Party or non-party that 23 designates information or items as Protected Material under this Order must take 24 care to limit any such designation to specific material that qualifies under the 25 appropriate standards. The parties agree that, where it would not be cost effective 26 to review every document for confidentiality issues, the parties may designate an 27 entire group of documents as "CONFIDENTIAL" or "HIGHLY 28 CONFIDENTIAL-ATTORNEYS’ EYES ONLY", including but not limited to the I I 5 STIPULATED PROTECTIVE ORDER I case of mass e-mail or internal document production. If the opposing party, upon 2 review, feels that a particular document is not properly "CONFIDENTIAL" or 3 "HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY", the party may 4 confer with the Designating Party, which shall withdraw the designation if 5 warranted. Absent agreement, the parties may seek Court relief as provided 6 7 herein. 4.2 Manner and Timing of Designations. Except as otherwise provided in 8 this Order (see, e.g., second paragraph of Section 4.2(a), below), or as otherwise 9 stipulated or ordered, material that qualifies for protection under this Order must 10 be clearly so designated before the material is disclosed or produced. Any party or 11 nonparty that is called upon to provide discovery in this action may designate any 12 Discovery Materials as CONFIDENTIAL or HIGHLY CONFIDENTIAL13 ATTORNEYS’ EYES ONLY under the terms of this Order. 14 (a) A party or non-party may designate as CONFIDENTIAL or 15 HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY as follows: 16 (i) for information in documentary form (apart from 17 transcripts of depositions or other pretrial or trial proceedings), that the Producing 18 Party affix the legend "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL- 19 ATTORNEYS’ EYES ONLY" to each page that contains Protected Material. 20 A Party or non-party that makes original documents or 21 materials available for inspection need not designate them for protection until 22 after the inspecting Party has indicated which material it would like copied and 23 produced. During the inspection and before the designation, all of the material 24 made available for inspection shall be deemed "CONFIDENTIAL" or "HIGHLY 25 1, CONFIDENTIAL-ATTORNEYS’ EYES ONLY." After the inspecting Party has 26 identified the documents it wants copied and produced, the Producing Party must 27 determine which documents, or portions thereof, qualify for protection under this 28 Order, then, before producing the specified documents, the Producing Party must 6 STIPULATED PROTECTIVE ORDER affix the appropriate legend "CONFIDENTIAL" or "HIGHLY CONFIDENTIALATTORNEYS’ EYES ONLY" at the top of each page that contains Protected Material. The Designating Party will bear the reasonable costs of producing and designating such Protected Materials. (ii) for testimony given in deposition, that the Party or nonparty offering or sponsoring the testimony identify on the record, before the close 7 of the deposition, that the deposition contains "CONFIDENTIAL" or "HIGHLY 8 CONFIDENTIAL-ATTORNEYS’ EYES ONLY" information. Within 30 days .9 after the deponent has circulated his/her changes to the deposition transcript or 10 confirmed that he/she has no changes to the deposition transcript, the Designating 11 Party shall identify the specific portions of the deposition testimony that contain 12 "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES 13 ONLY" information. The remaining portions of the deposition transcript neither 14 designated as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL" shall no 15 16 longer be subject to this Order. (iii) for information produced in some form other than 17 documentary, and for any other tangible items, that the Produing Party affix in a 18 prominent place on the exterior of the container or containers in which the 19 information or item is stored the legend CONFIDENTIAL" or "HIGHLY 20 CONFIDENTIAL-ATTORNEYS’ EYES ONLY." 21 4.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 22 failure to designate qualified information or items as "CONFIDENTIAL" or 23 "HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY" does not, standing 24 alone, waive the Designating Party’s right to secure protection under this Order for 25 such material. If material is appropriately designated as "CONFIDENTIAL" or KIM "HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY" after the material 27 was initially produced, the Receiving Party, on timely notification of the 7 STIPULATED PROTECTIVE ORDER 1 designation, must make reasonable efforts to assure that the material is treated in 2 accordance with the provisions of this.Order. 3 41 5. CHALLENGING DESIGNATIONS. 5.1 Timing of Challenges. A Party does not waive its right to challenge a 5 confidentiality designation by electing not to mount a challenge promptly after the .6 original designation is disclosed. In all cases, however, the Parties shall endeavor 7 to identify at the earliest opportunity those designations that they. oppose, 8 5.2 Meet and Confer. A Party that elects to initiate a challenge to a 9 Designating Party’s confidentiality designation must do so’ good faith and must 10 begin the process by identifying the confidentiality designation it is challenging, 11 explaining the basis for its belief that. the confidentiality designation was not 12 proper and conferring directly with counsel for the Designating Party in 13 . accordance with CivilLoaiRule 37-1. The Designating Party, after it has had an 14 opportunity to review the designated material and to reconsider the circumstances 15 for the designation, and if no change in designation is offered, is to respond in 16 writing to the challenging Party’s grounds and challenges, and to provide a good 17 faith explanation for the basis of the chosen designation. The Parties should then 18 proceed to the next stage of the challenge process only if it has engaged in this 19 meet and confer process first. 20 5.3 Judicial Intervention. A Party that elects to press a challenge to a 21 confidentiality designation after the meet and confer process may proceed 22 pursuant to Civil Local Rules 37-2 and 37-3 and, if applicable, Civil Local Rule 23 79-5, and must identify in the submissions to the Court the challenged material 24 and set forth in detail the basis for the challenge. Upon any hearing, the initial 25 burden of proof shall be on the party challenging the designations. The Party 26 challenging the designation must show more than a mere disagreement. over the 27 designation. The challenging Party must establish that the protected material was 28 wrongly designated and show a compelling need to have it redesignated. Upon 8 STIPULATED PROTECTIVE ORDER ] such a showing, the burden of persuasionthat the material: has been properly 2 designated shifts to the Designating Party. Until the Court rules on the challenge, 3 all parties shall continue to afford the material in question the level of protection 4 to which it is entitled under the Designating Party’s designation. 5 6 6. ACCESS TO AND USE OF PROTECTED MATERIAL. 6.1 Basic PrinciDles. A Receiving Party may use Protected Material that 7 is disclosed or produced by another Party or by a non-party in connection with this 8 case only for prosecuting, defending, or attempting to settle this litigation. Such 91, Protected Material may be disclosed only to the categories of persons and under 10 the conditions described in this Order. When the litigation has been terminated, a 11 Receiving Party must comply with the provisions of Section 10, below (FINAL 12 DISPOSITION). 13 Protected Material must be stored and maintained by a Receiving Party at a 14 location and in a secure manner that ensures that access is limited to the persons 15 authorized under this Order. 16 6.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless 17 otherwise ordered by the Court or permitted in writing by the Designating Party, a 18 Receiving Party may disclose any information or item designated 19 "CONFIDENTIAL" only to: 20 (a) the officers, directors, and employees (including House 21 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for 22 23 this litigation; (b) the Receiving Party’s Outside Counsel of record in this action, 24 as well as employees of said Counsel; 25 (c) independent experts (as defined in this Order) not employed by 26 any party who have been specifically retained by a party to give expert testimony 27 or otherwise assist in the preparation of this action for trial and who have signed 28 9 STIPULATED PROTECTIVE ORDER 1 the "Acknowledgment and Agreemetif to Be Bound by Protective Order" 2 (Exhibit A); 3 (d) the Court and its personnel; 4 (e) 5 court reporters, their staffs, and Professional Vendors retained by Counsel to whom disclosure is reasonably necessary for this litigation and 6 provided that Counsel ensures the Professional Vendors’ compliance with this 7 Order; 8 9 (f) during their depositions and in preparation for their depositions, or at trial and during trial preparation, witnesses in the action to 10 whom disclosure is reasonably necessary. Pages of transcribed deposition 11 testimony or exhibits to depositions that reveal Protected Material must be 12 separately bound by the court reporter and may not be disclosed to anyone except 13 14 ’1 5 16 as permitted under this Protective Order; and (g) the author or, any recipient of the document or the original source of the information. (h) the insurer, reinsurer, auditor, attorney, or accountant of any of 17 the above, but only to the extent reasonably necessary and required by the insurer, 18 reinsurer, auditor, attorney or accountant to discharge his, her, or its official or 19 contractual duties. 20 6.3 Disclosure of "HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES 21 ONLY" Information or Items. Unless otherwise ordered by the Court or permitted 22 in writing by the Designating Party, a Receiving Party may disclose any 23 information or item designated "HIGI-ILY CONFIDENTIAL-ATTORNEYS’ 24 EYES ONLY" only to those persons described in Paragraphs 6.2(b) through (e), 25 and (g), above. If a party believes it is reasonably necessary to allow the 26 disclosure of "HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY" 27 Discovery Materials to other persons or categories of persons, but the parties 28 STIPULATED PROTECTIVE ORDER 1 cannot reach an agreement after meeting and conferring, the party may move the 2 Court to permit such disclosure for good cause. 3 7. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 4 IN OTHER LITIGATION. 5 If a Receiving Party is served with a subpoena or an order issued in other 6 litigation or administrative proceeding, or before any deliberative body, that 7 would compel disclosure of any information or items designated in this action as S "CONFIDENTIAL" or ’HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES 9 ONLY," the Receiving Party is to notify all Parties, in writing (by fax, if possible) 10 as soon as reasonably possible after receiving the subpoena or order. Such 11 notification must include a copy of the subpoena or court order. The Parties 12 understand and agree that the purpose of requiring the Receiving Party to notify 13 all Parties of the subpoena is to provide the Parties with sufficient time to file a 14 request for a protective order or motion to quash the subpoena. The Receiving Party also must immediately inform in writing the Party that 15 16 caused the subpoena or order to issue in the other litigation that some or all the 17 material covered by the subpoena or order is the subject of this Protective Order. 18 In addition, the Receiving Party must deliver a copy of this Protective Order 19 promptly to the Party in the other action that caused the subpoena or order to 20 .21 issue. The purpose of imposing these duties is to alert the interested parties to the 22 existence of this Protective Order and to afford any Party hereto an opportunity to 23 try to protect its confidentiality interests in the court or body from which the 24 subpoena or order issued. The Party seeking such protection shall bear the burdens 25 and the expenses of seeking protection of its confidential material in that court, 26 and nothing in these provisions should be construed as authorizing or encouraging 27 a Receiving Party in this action to disobey .a lawful directive from another court or 28 deliberative body. 11 STIPULATED PROTECTIVE ORDER :j.. 8. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL. 2 If a Receiving Party learns that, by inadvertence or otherwise, it has 3 disclosed Protected Material to any person or in any circumstance not authorized 4 under this Protective Order, the Receiving Party must immediately (a) notify in 5 writing all other Parties of the unauthorized disclosures, (b) use its best efforts to 6 retrieve all copies of the Protected Material, (c) inform the person or persons to 7 whom unauthorized disclosures were made of all the terms of this Protective 8 Order, and (d) request such person or persons to execute the "Acknowledgement 9 and Agreement to Be Bound by Protective Order" (Exhibit A). 10 9. FILING PROTECTED MATERIAL, 11 In the event that any party intends to include any document designated as 2 "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES 13 ONLY" under this Protective Order as part of any motion, opposition, reply or 14 other document, including, any declarations: (collectively "Filing") to be filed with 15 the Court, the Filing shall be made under seal. Alternatively, if the 16 CONFIDENTIAL and HIGHLY-CONFIDENTIAL ATTORNEYS’ EYES ONLY 17 Discovery Material can be redacted to obviate the need to file documents under 18 seal, such as, by example, redacting names, addresses, amounts, or other 19 confidential information, and, if appropriate, substituting generic identifiers, the 20 Parties shall work together to agree to the appropriate redactions. 1 The parties understand that all Court orders will be presumptively 22 available to the public. Therefore all papers submitted to the Court that 23 quote or set forth "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL24 ATTORNEYS’ EYES ONLY" information shall designate the particular 25 : information that is designated "CONFIDENTIAL" or "HIGHLY 26 CONFIDENTIAL-ATTORNEYS’ EYES ONLY." This will enable the Court, 27 in drafting orders, to determine whether there is evidence which the Court 28 should attempt not to disclose. Absent such advance notification (and even 12 STIPULATED PROTECTIVE ORDER :1,:: with such notification to the extent the Court believes it appropriate), the 2 Court remains free to incorporate and publicly disclose all such evidence in 3 its written and oral rulings if it concludes that this information is neither 4 ".CONFIDENTIAL": or "HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES 5 ONLY" information. 6 The parties further understand that in the event that the case proceeds 7 to trial, and the parties use information that was designated as 8 "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES 9 ONLY," and/or kept and maintained pursuant to the terms of this Protective 10 Order at trial, such information may become public and in such case will be 11 presumptively available to all members of the public, including the press, .12 unless sufficient cause is shown to proceed otherwise. 13 10. FINAL DISPOSITION. 14 Unless otherwise ordered or agreed in writing by the Producing Party, 15 within sixty (60) days after the final termination of this action, each Receiving 16 Party must return all Protected Material to the Producing Party. As used in this 17 subdivision, "all Protected Material" includes all copies, abstracts, compilations, 18 summaries or any other form of reproducing or capturing any of the Protected 19 Material. With permission in writing from the Designating Party, the Receiving 20 Party may destroy some or all of the Protected Material instead of returning it. 21 Whether the Protected Material is returned or destroyed, the Receiving Party must 22 submit a written certification to the Producing Party (and, if not the same person 23 or entity, to the Designating Party) by the sixty-day deadline that identifies (by 24 category, where appropriate) all the Protected Material that was returned or 25 destroyed and that affirms that the Receiving Party has not retained any copies, 26 abstracts, compilations, summaries or other forms of reproducing or capturing any 27 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 28 retain an archival copy of all pleadings, motion papers, transcripts, legal 13 STIPULATED PROTECTIVE ORDER J memoranda, correspondence or attorney work product, even if such materials 1. 2 contain Protected Material. Any, such archival copies that contain or constitute 3 Protected Material remain subject to this Protective Order as set forth in Section 3 4 (DURATION), above. The Courtts jurisdiction to enforce the terms of the Order 5 shall continue afterthe final conclusion of all aspects of the litigation. 6 11. CLAW BACK. 7 The inadvertent production of any document, electronically stored 8 information,material or other information during discovery in this action shall be 9 without prejudice to any claim that such material is privileged under the attorney1’0 client privilege or protected from discovery as work product within the meaning ii of Rule 26 of the Federal Rules of Civil Procedure, and no party shall be held to 12 have waived any rights by such inadvertent production. Upon discovery of such 13 inadvertent production, a Producing Party may notify the Receiving Party and 14 request return of any such document or information, as well as any and all copies 15 which may have been made by the Receiving Party. 16 12. MISCELLANEOUS. 111 Right to Further Relief. Nothing in this Order abridges the right of 17 18 any person to seek its modification by the Court in the future. 12.2 Right to Assert Good Faith Objections. By stipulating to the entry of 19 20 this Protective Order no Party waives any right it otherwise would have to object 21 in good faith to disclosing or producing any information or item on any ground 22 not addressed in this Protective Order. Similarly, no Party waives any right to 23 object on any good faith ground to use in evidence of any of the material covered 24 by this Protective Order. 25 III .26 I/I 27 III 28 III 14 STIPULATED PROTECTIVE ORDER 1 AGREED TO: .2 Dated: March 26, 20 14 MORRIS POLICH & FUR DY LLP 3 . 4 5 6 7 8 . All of the following signatories concur in the filing’s content and have authorized 9 the filing. 10 Dated: March 26,2014 JAMES K. CAMERON & ASSOCIATES, APC [1 12 By: Is! James K. Cameron James K. Cameron Attorneys for Defendants ESTATE OF RICI-TARD C. CORRALES and SANDRA FAVILA and CounterClaimants ESTATE OF RICHARD C. CORRALES and MOTION GRAPHIX, INC. 13 14 15 16 17 Dated: March 26, 2014 LAW OFFICE OF GARY R. WALLACE .18 19 By: Is! Gary R. Wallace Gary R. Wallace Attorneys for Defendants ESTATE OF RICHARD C. CORRALES and SANDRA FAVILA and CounterClaimant ESTATE OF RICHARD C CORRALES 20 21 22 23 24 S So Tr2 2.6 27 28 STIPULATED PROTECTIVE ORDER 1 IIDt: March 26, 2014 CARLOS F. NEGRETE LAW OFFICES 2 3 4 5 6 7 .8 By: Is! Carlos F. Negrete Carlos F. Negrete Attorneys for Plaintiff MOOFLY PRODUCTIONS, LLC and for Counter-Defendants MOOFLY PRODUCTIONS, LLC; HELENA PASQUARELLA; GET FLIPPED, INC. THE KISS OF LIGHT TRUST DATD AUGUST 31, 2002 and RALEIGH WILLIAM SOUTHER 9 Dated: March 26, 2014 10 WALTON & WAL’rOiN, LLP 11 By: Is! L. Richard Walton L. Richard Walton Samuel J. Levy Attorneys for Third Party Defendants THOMAS JOEL and JOEL MEDIA GROUP 12 13 14:: 15 16 1.7 18 19 20 21 22 23 24 25 26 27 2 8 16 STIPULATED PROTECTIVE ORDER .1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT 3 TO BE BOUND BY PROTECTIVE ORDER 4 [print or type full name] of 5 [print or type full address] declare under penalty of perjury under the laws of the United States and California that I have 7 read in its entirety and understand the Stipulated Protective Order that was issued 8 . by the United States District Court for the Central District of California on 9 .. [date] in the case of Moofly Productions, Inc. v. Favila, et al., 10 Case No. CV-5866 RSWL ("Protective Order"). I agree to comply with and to be 11 bound by all the terms of this Protective Order. I solemnly promise that I will not 12 disclose in any manner any information or item that is subject to this Protective 13 Order to any person or entity except in strict compliance with the provisions of 14 this Protective Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for the purpose of enforcing the terms 17 of the Protective Order, even if such enforcement proceedings occur after 18 termination of this action. 19 .20 I hereby appoint . .. [print or type full name] of: 21 22 23 24 25 [print or type full address and telephone number] as my California agent for service of process in connection with this action or any 26 proceeding related to enforcement of this Protective Order, 27 28 Date: STIPULATED PROTECTIVE ORDER

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