David Velasco et al v. Paccar Inc et al

Filing 34

PROTECTIVE ORDER GOVERNING THE TREATMENT OF CONFIDENTIAL INFORMATION by Judge Manuel L. Real re Stipulation for Protective Order 33 (pj)

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1 2 3 4 5 6 7 8 9 10 JASON H. ANDERSON, State Bar No. 172087 janderson@sycr.com CRAIG A. TAGGART, State Bar No. 239168 ctaggart@sycr.com STEPHAN L. RAM, State Bar No. 240769 sram@sycr.com STRADLING YOCCA CARLSON & RAUTH, P.C. 660 Newport Center Drive, Suite 1600 Newport Beach, CA 92660-6422 Telephone: (949) 725-4000 Facsimile: (949) 725-4100 Attorneys for Defendant WESTPORT FUEL SYSTEMS INC. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DAVID VELASCO, YAMINA CASE NO. CV 13-09407-R (AS) RODRIGUEZ, ALVARO HERNANDEZ, CARLOS ORDER GOVERNING THE QUIROA, CLOVIS GONZALES, TREATMENT OF CONFIDENTIAL DARNELL YOUNG, JOSE INFORMATION VELASCO, EDUARDO GRIJALVA, EFRAIN LARA, Ctrm: 8 EMMANUEL VASQUEZ, ERVIN Judge: Hon. Manuel L. Real MIDENCE, ESLY NAHUN LOYO, GEOVANY MENDIETA, GLORIA MENDIETA, ILARIO JULIO VAQUERANO, JAIRO CERROS, JORGE GUEVARA, JUAN MUNOZ, KEVIN RODAS, LUIS MIDENCE, MARVIN ESTRADA, PEDRO DAVID ALAS RAMIREZ, ROGELIO RODRIGUEZ, WILFREDO REYES, DAVID BANDA, RAMON GUERRERO, JAVIER PEREZ, MARVIN CABALLERO, FRANCISCO CABALLERO, GARRY EBALOBUR, LUIS MARTINEZ, DOUGLAS ROMERO, ALVARO ARAMBULA, MARIA FRANCO, FRANCISCO HERNANDEZ, TONY RIVERA, JORGE GONZALES, HECTOR MARTINEZ, FRANCISCO CHAVEZ, EDWIN QUINONEZ, OSWALDO MELO, CAMILIO CEBALLAS, NOE RODRIDGUEZ, MARIN CAMPOS, JORGE PALACIOS, JESSE PEREZ, JOSE S TRADLING Y OCCA C ARLSON & R AUTH PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001 1 2 3 4 5 6 7 8 9 10 11 12 13 AGUILAR, GUILLERMO CASILLAS, KIM MACARAEG, HERMINIO MARTINEZ, FREDY RAMIREZ, DENNIS VEGA, ALVARO ARCILA, JOSE A. FUENTES, JUAN MARTINEZ, GUSTAVO PALENCIA, PATRICK VO, JOSE CRUZ ROSAS ESPINOZA, JUAN R GONZALEZ, ARLIRIO S. CACERES AVELAR, and FRANCISCO MENDEZ, individually and on behalf of all similarly-situated consumers Plaintiffs, vs. PACCAR INC., KENWORTH TRUCK COMPANY, INLAND KENWORTH (US), Inc., and WESTPORT FUEL SYSTEMS INC. Defendants. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 S TRADLING Y OCCA C ARLSON & R AUTH ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N EWPORT B EACH LITIOC/2095071v1/103002-0001 1 IT IS HEREBY ORDERED as follows: 2 1. This Stipulation and Order Governing the Treatment of Confidential 3 Information (the “Stipulation”) shall govern the disclosure and use of Confidential 4 Discovery Material (as defined below) and all other discovery material as 5 applicable provided during the course of this Action by the Parties to the Action or 6 by nonparties, either voluntarily or as required by discovery demands made 7 pursuant to the Federal Rules of Civil Procedure. 8 2. As used in this Stipulation, “person” includes any individual, entity, 9 natural person, or any business, legal or governmental entity or association. 10 “Producing Person” refers to any person that produces discovery material. 11 “Receiving Person” refers to any person that receives discovery material subject to 12 this Stipulation. 13 3. This Protective Order designates as “Confidential Discovery 14 Material” documents or discovery responses that may be produced during 15 discovery that are designated as such by a Producing Person because they contain 16 any of the following: confidential, sensitive, or nonpublic financial information 17 and statements; proprietary business information, including trade secrets, business 18 plans and records of internal deliberations and decision-making; policies and 19 procedures not generally published, including those concerning business 20 operations, employee benefits and risk management procedures; surveys 21 concerning customers, competitors and employees; and individual personal 22 information that is protected from disclosure under state or federal law, including 23 identifying personal information and personal financial information, about any 24 Party, any employee of any Party, or any third party. It is possible that disclosure 25 of this Confidential Discovery Material may cause harm to the Producing Persons 26 and their employees, as well as to third parties. Confidential Discovery Material 27 also includes documents that have not been produced in discovery, but which are 28 filed under seal with the Court. -1- S TRADLING Y OCCA C ARLSON & R AUTH PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001 1 4. All documents designated as Confidential Discovery Material shall be 2 so designated, by Bates range, in a letter accompanying their production to a Party, 3 by stamping the media in which the documents are transmitted, or by stamping the 4 first page of a document “CONFIDENTIAL,” “CONFIDENTIAL DISCOVERY 5 MATERIAL,” or “CONFIDENTIAL TREATMENT REQUESTED BY [and the 6 name of the producing party].” Documents may be designated as Confidential 7 Discovery Material at any time. Without limiting the foregoing sentence in any 8 way, a Party may designate a document as CONFIDENTIAL after it was earlier 9 produced without such a designation, and such production, in and of itself, shall 10 not prejudice or otherwise constitute a waiver of, or estoppel as to, any claim of 11 confidentiality to which the Producing Person would otherwise be entitled. Any 12 documents designated as Confidential Discovery Material prior to entry of this 13 Order shall be treated the same in all respects as documents designated as 14 Confidential Discovery Material after the entry of this Order. By designating a 15 document as Confidential, the parties do not waive their right to redact information 16 on privilege or other grounds. This Order also treats as Confidential Discovery 17 Material certain deposition testimony designated as confidential either orally 18 (provided that such designation was recorded by a court reporter) or in writing. 19 Documents that are filed with the Court under seal shall be treated as Confidential 20 Discovery Material whether or not the documents have been produced. 21 5. It is the intent of the Parties and the Court that materials will not be 22 designated as Confidential Discovery Material for tactical reasons in this case and 23 that nothing will be so designated without a good faith belief that there is good 24 cause why it should not be part of the public record in this case. 25 6. Confidential Discovery Material also includes those portions of any 26 notes, work papers or other work product that contain confidential information 27 from documents designated as Confidential Discovery Material without the need 28 for a separate confidential designation on the notes, work paper, or other work -2- S TRADLING Y OCCA C ARLSON & R AUTH PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001 1 product. 2 7. If discovery material is inspected at the Producing Person’s choice of 3 location, all such discovery material shall be presumed at such inspection to have 4 been designated as Confidential Discovery Material by the Producing Person until 5 such time as the Producing Person provides copies to the Party that requested the 6 discovery material. Production of Confidential Discovery Material for inspection 7 and copying shall not constitute a waiver of confidentiality. 8 9 8. Confidential Discovery Material shall be subject to the following restrictions: 10 (a) Confidential Discovery Material shall be used solely for the 11 purpose of preparing for, and conducting, the prosecution or defense of this Action, 12 including any appeals thereof, and shall not be used by the Parties or any other 13 person for any commercial, business, competitive or other purpose. 14 (b) Confidential Discovery Material shall not be given, shown, 15 made available or communicated in any way to anyone except those persons 16 specified in subparagraph (c) below to whom it is necessary that such Confidential 17 Discovery Material be given or shown for the purposes permitted under 18 subparagraph (a) above. Where information is sensitive and cannot be provided to 19 any persons other than the attorneys associated with the case, the parties shall 20 designate such documents as “CONFIDENTIAL ATTORNEYS’ EYES ONLY,” 21 which shall limit review to only those persons set forth in subparagraph (c)(i) 22 below. The parties agree to meet and confer regarding such materials in good faith 23 to determine whether they can reach an agreement on any other persons that can be 24 given or shown such materials. 25 (c) Confidential Discovery Material may be disclosed, for the 26 purposes set forth in subparagraph (a) above, only to a “Qualified Person,” defined 27 as follows: 28 (i) S TRADLING Y OCCA C ARLSON & R AUTH counsel of record for the Parties, and attorneys, paralegal, -3PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001 1 clerical and other staff employed or retained by such counsel who are assisting in 2 the conduct of the Action; 3 (ii) those officers, directors, and representatives (including 4 legal representatives) of the Parties deemed necessary to aid counsel in the conduct 5 of the Action; 6 7 (iii) any and all individual Plaintiffs or Defendants in this (iv) witnesses (other than Parties) at any deposition or Action; 8 9 hearing in the Action; 10 (v) such consultants, experts, and investigators (including 11 their professional staffs) retained by the Parties, or their respective counsel, as they 12 in good faith deem necessary to provide assistance in connection with the conduct 13 of the Action; 14 15 (vi) alternate jurors; 16 17 the Court, court personnel, and jurors, potential jurors or (vii) court reporters and videographers used in connection with the conduct of this Action; 18 (viii) outside photocopying, graphic production services, 19 litigation support services, and document hosting vendors retained by the Parties, 20 or their respective counsel, as they in good faith deem necessary to provide 21 assistance in connection with the conduct of the Action; 22 23 (ix) persons who are or were authors or recipients of the Confidential Discovery Material; and 24 (x) any person carrying on an insurance business that may be 25 liable to satisfy part or all of any judgment which may be entered in the action or to 26 indemnify or reimburse for payments made to satisfy a judgment. 27 28 S TRADLING Y OCCA C ARLSON & R AUTH 9. Except for Qualified Persons defined in subsections 8(vi), 8(vii), and 8(viii), each person described in subparagraph 8(c) to whom Confidential -4PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001 1 Discovery Material is disclosed shall first be advised that such Confidential 2 Discovery Material is being disclosed pursuant and subject to the terms of this 3 Stipulation and that Confidential Discovery Material may not be disclosed other 4 than pursuant to the terms hereof. Prior to disclosing Confidential Discovery 5 Material to any person described in subparagraph 8(c)(v) above, counsel shall 6 cause each such person to execute a Certificate in the form annexed hereto as 7 Exhibit A. Counsel shall be responsible for retaining executed certificates. 8 9 10. If any Receiving Person inadvertently discloses Confidential Discovery Material to persons who are not Qualified Persons, such disclosure shall 10 be reported in writing, via overnight delivery service or email, to the Producing 11 Person who produced such inadvertently disclosed Confidential Discovery 12 Material within three (3) business days of the discovery of such disclosure. In that 13 event, counsel for the Receiving Person shall make all reasonable efforts to retrieve 14 the Confidential Discovery Material and to obtain the agreement of persons to 15 whom inadvertent disclosure was made to treat the Confidential Discovery 16 Material in accordance with the terms of this Stipulation. 17 11. Information or testimony disclosed at a deposition may be designated 18 as Confidential Discovery Material by the person providing such testimony, by a 19 Party, or by a Producing Person if such person either: (a) identifies on the record at 20 the deposition those portions of the testimony that are designated as Confidential 21 Discovery Material; or (b) provides written notification to all Parties within thirty 22 (30) days of the court reporter’s release of the transcript of the deposition as to 23 those pages and lines of the transcript that are designated as Confidential 24 Discovery Material. Except to the extent the Parties otherwise agree, the entire 25 transcript of any deposition shall be treated as Confidential Discovery Material for 26 seven (7) days after the court report’s release of the transcript where a party has 27 stated at the deposition, or immediately thereafter, that portions of the transcript 28 contain Confidential Discovery material. Each page of a deposition transcript -5- S TRADLING Y OCCA C ARLSON & R AUTH PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001 1 designated as Confidential shall be stamped, as set forth in paragraph 4 above, by 2 the court reporter or by counsel. If counsel for any Party believes that a question 3 put to a witness being examined in pretrial deposition will disclose Confidential 4 Discovery Material, or that the answer to any question or questions requires such 5 disclosure, or if documents to be used as exhibits during the examination contain 6 such Confidential Discovery Material, such counsel may so notify requesting 7 counsel, and, in that event, that portion of the deposition shall be taken in the 8 presence only of counsel, parties to the Litigation, the court reporter, video 9 operator and heir assistants, and persons who have signed a receipt acknowledging 10 the receipt of this Protective Order. The court reporter shall indicate in the 11 transcript the portion of the transcript that is to be kept confidential, and shall mark 12 the cover page of the transcript accordingly. 13 12. In the event that any person discloses Confidential Discovery Material 14 in any pleading, court filing, attachment or exhibit thereto, or other papers filed 15 with the Court pre-trial, the disclosing person shall conditionally file the 16 confidential information under seal with the Clerk of this Court pursuant to Local 17 Rule 79-5; provided, however, that the paper shall be furnished to the Court and 18 the attorneys for the Parties and a duplicate copy with the confidential information 19 deleted will be placed in the public record insofar as possible. The Parties 20 understand that designation of materials as Confidential Discovery Material does 21 not automatically entitle the Parties to have such information kept under seal and 22 that any submission of documents under seal should seek to file under seal only 23 those portions of the documents that contain confidential information, see, e.g., 24 Kamaka v. City & County of Honolulu, 447 F.3d 1172, 1178-81 (9th Cir. 2006), 25 and should be made to the judicial officer presiding over the proceedings in 26 question. This Protective Order does not address the use of Confidential Discovery 27 Material for use at trial. The Parties agree to meet and confer regarding use of 28 Confidential Discovery Material in connection with trial and to raise the issue with -6- S TRADLING Y OCCA C ARLSON & R AUTH PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001 1 2 the Court at an appropriate time. 13. No Party concedes that any discovery material designated by any 3 other person as Confidential Discovery Material under any provision of this 4 Stipulation in fact contains or reflects trade secrets, proprietary or confidential 5 information, or has been properly designated as Confidential Discovery Material, 6 and entering into this Stipulation shall not prejudice the right of a Party to seek, at 7 any time, a determination by the Court of whether any particular document or 8 information should be subject to the terms of this Stipulation. 9 14. A Receiving Person shall not be obliged to challenge the propriety of 10 a designation of documents or other material as Confidential Discovery Material at 11 the time made, and failure to do so shall not preclude a subsequent challenge 12 thereof. If at any time a Receiving Person objects to a Confidential Discovery 13 Material designation under this Stipulation, the Objecting Party shall notify the 14 Producing Person in writing. The Objecting Party shall identify the information in 15 question and shall specify in reasonable detail the reason or reasons for the 16 objection, and shall otherwise comply with Local Civil Rule 37-1. Within ten (10) 17 calendar days of the receipt of such written notice, the Producing Person and 18 Objecting Party shall meet-and-confer in an effort to resolve their differences. If 19 the disagreement cannot be resolved, the Producing Person may apply to the Court 20 within ten (10) calendar days for a protective order affirming the Producing 21 Person’s Confidential Discovery Material designation. The application of the 22 Producing Person shall comply with Local Civil Rules 37-2 and 37-3, and the 23 Producing Person shall have the burden of demonstrating that the document or 24 material designated as Confidential Discovery Material is deserving of confidential 25 treatment or other protection under the terms of this Stipulation. If the Producing 26 Person does not make such an application to the Court, the documents or material 27 to which an objection was directed will no longer be considered Confidential 28 Discovery Material under this Stipulation. While any such application is pending, -7- S TRADLING Y OCCA C ARLSON & R AUTH PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001 1 the documents or material subject to that application will remain Confidential until 2 the Court rules. 3 15. In the event that the Court determines that there is an actual or 4 threatened breach of the agreement by a Receiving Person, the Parties agree that 5 the Producing Person would not have an adequate remedy at law and would be 6 entitled to specific performance, and/or injunctive relief, to enforce the terms of 7 this Protective Order, in addition to any other remedy the party may be entitled at 8 law or in equity. 9 16. If any Receiving Person (a) is subpoenaed in another action, (b) is 10 served with a demand in another action to which he, she, or it is a party, or (c) 11 receives a demand or request for documents from a legal or regulatory organization 12 with jurisdiction over it and such subpoena, demand or request seeks Confidential 13 Discovery Material under the Stipulation, the Receiving Person shall (unless 14 prohibited by law or regulation) give written notice, by hand or by e-mail, within 15 seven (7) business days of receipt of such subpoena, demand, or request for 16 documents to all Parties, and to any Non-Party who produced or designated the 17 discovery material as Confidential, and in no event shall produce such requested 18 material prior to providing such notice. Any Party or Producing Person may seek a 19 protective order or similar court-ordered relief to prevent the requested production. 20 Should a Party or Producing Person seek a protective order or similar court- 21 ordered relief, then the Receiving Person shall not produce any of the Producing 22 Person’s Confidential Discovery Material, until a final decision that is no longer 23 subject to appellate review orders such production, provided that a Party or 24 Producing Person must file a Notice of Appeal or Motion for permission to Appeal 25 from a lower court order not later than thirty (30) days after Notice of Entry of that 26 order is served. If a Party is subpoenaed or requested to produce Confidential 27 Discovery Material by a regulatory or self-regulatory agency with jurisdiction over 28 it, through a process which by law, regulation, interpretive letter, regulatory policy -8- S TRADLING Y OCCA C ARLSON & R AUTH PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001 1 or compulsory process, requires the Party to produce requested materials without 2 objection, notice to other parties or delay, it shall be permitted to do so 3 notwithstanding any provisions of this Order, including the advance notice 4 provisions, to the contrary. 5 17. Absent consent from a Producing Person, no Confidential Discovery 6 Material produced by such Producing Person may be used in connection with any 7 other litigation, matter, or proceeding. 8 9 18. Upon notification that a document or other discovery material has been inadvertently produced and/or that a claim of attorney-client privilege, 10 attorney work product, or other applicable privilege or protection will be made 11 with regard to such document or other discovery material, the party receiving such 12 notice shall promptly return or, at the Producing Person’s option, destroy any and 13 all copies of such document or other discovery material and shall refrain from 14 reading or reviewing said document or discovery material beyond the extent 15 necessary to identify it as the inadvertently produced material, or from utilizing it 16 in any manner or form including specifically but not exclusively, use during the 17 course of a deposition, review with witnesses, or any other disclosure or review 18 whatsoever. The Receiving Person shall also remove all references to such 19 material from any attorney work product. Together with notification of inadvertent 20 production, the Producing Person shall supply a privilege log to the Receiving 21 Person describing said document or other discovery material in compliance with 22 Rule 26(b)(5)(A) of the Federal Rules of Civil Procedure. The inadvertent 23 production of any document or discovery that is subsequently retrieved or 24 destroyed pursuant to this paragraph shall not be deemed to be a waiver of the 25 claim of privilege or protection asserted. Notwithstanding the foregoing, nothing 26 in this paragraph shall prevent a Receiving Person, after promptly returning or 27 destroying the discovery material, from challenging the Producing Person’s 28 designation of the document or discovery as subject to attorney client privilege, -9- S TRADLING Y OCCA C ARLSON & R AUTH PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001 1 attorney work product, or other applicable privilege or protection or otherwise not 2 subject to production, provided that (a) such challenge complies with Local Rules 3 37-1 through 37-4, (b) any review by the Court of the materials in question is 4 conducted in camera, and (c) the challenge shall not assert as ground or basis that 5 the Producing Person waived any privilege or protection because of the inadvertent 6 disclosure. 7 19. This Stipulation shall be without prejudice to the rights of a Producing 8 Person to seek further limits on disclosure or protections for the confidentiality of 9 any discovery material (whether or not designated as Confidential) in addition to 10 the limits and protections provided herein, including, without limitation, that 11 access or disclosure of any discovery material be limited solely to counsel for a 12 Party or to other specified persons and without prejudice to the rights of any other 13 person to contest such application. 14 20. Other Parties and Third Parties. Other parties to this Litigation, 15 including any additional parties that join or are joined in this Litigation, may have 16 access to Confidential Discovery Material only by additional order of the Court or 17 by the party’s executing and filing with the Court a stipulation agreeing to be fully 18 bound by this Protective Order. Third parties providing discovery materials in 19 response to a subpoena may gain the benefits of this Order with respect to any 20 documents or discovery materials they produce by executing a Certificate in the 21 form annexed hereto as Exhibit A; by so signing, those parties will also assume all 22 the duties and obligations required under this Order. 23 21. Within thirty (30) days after the final termination of this Litigation, 24 including any appeals, each counsel shall at the option of the disclosing party 25 either return all Confidential Discovery Material in his possession, custody or 26 control, and all copies, portions, summaries, or abstracts thereof to counsel for the 27 disclosing party or shall certify destruction thereof; provided, however, that 28 counsel for a party may retain a file copy of work product created in connection -10- S TRADLING Y OCCA C ARLSON & R AUTH PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001 1 with this Litigation that includes Confidential Discovery Material, but such work 2 product shall continue to be kept confidential pursuant to this Protective Order. 3 4 5 22. The Parties may jointly seek to amend or modify this Stipulation subject to Court approval. 23. Notwithstanding any provision contained herein, nothing in this 6 Stipulation shall restrict in any way the right of a Party to make use of its own 7 discovery material in any way it deems fit. 8 24. Nothing in this Protective Order shall be deemed a waiver of any of 9 the Parties’ rights to oppose any discovery on any grounds or to object on any 10 ground to the admission in evidence at any motion hearing or the trial of this 11 Litigation of any matter discovered. 12 13 14 Date: May 8, 2014 15 _________________________________ HON. MANUEL L. REAL UNITED STATES DISTRICT JUDGE 16 17 18 19 20 21 22 23 24 25 26 27 28 -11- S TRADLING Y OCCA C ARLSON & R AUTH PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001 1 EXHIBIT A 2 AGREEMENT TO BE BOUND BY STIPULATION AND ORDER 3 GOVERNING THE TREATEMENT OF CONFIDENTIAL INFORMATION 4 5 I hereby certify that I have been provided with a copy of the Stipulation and 6 Order Governing the Treatment of Confidential Information (the “Stipulation”) 7 entered in the United States District Court for the Central District of California on 8 _______________ 2014 in the action titled Velasco, et al. v. PACCAR, et al., 9 CASE NO. CV 13-09407-R (AS). 10 I have read the Stipulation and I agree to be bound by its terms and 11 conditions governing the disclosure of Confidential Discovery Material (as defined 12 in the Stipulation). 13 I hereby consent to the exercise of jurisdiction over me in the United States 14 District Court for the Central District of California in connection with any 15 proceedings relating to the Stipulation, including but not limited to any action to 16 enforce its terms and conditions. 17 18 19 20 21 22 23 Print name: _______________________________ Firm/company: ____________________________ Signature: ________________________________ Dated: ___________________________________ 24 25 26 27 28 -1- S TRADLING Y OCCA C ARLSON & R AUTH PROPOSED ORDER RE: CONFIDENTIAL INFORMATION LAWYERS N E W P O R T B E AC H LITIOC/2095071v1/103002-0001

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