Nelson Levine De Luca & Hamilton, LLC v. Lewis Brisbois Bisgaard & Smith LLP

Filing 61

PROTECTIVE ORDER by Magistrate Judge Stephen J. Hillman re Stipulation for Protective Order 60 (sbu)

1
2
3
4
5
6
7
8
9
10
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

11
12
13
14
15

MICHAEL R. MATTHIAS, Bar No. 57728
[e-mail]
ROBERT C. WELSH, Bar No. 130782
[e-mail]
BAKER & HOSTETLER LLP
11601 Wilshire Boulevard, Suite 1400
Los Angeles, California 90025-0509
Telephone: [phone]
Facsimile: 310.820.8859
Attorneys for Plaintiff
NELSON LEVINE DE LUCA
& HAMILTON, LLC
PARKER MILLS LLP
David B. Parker (SBN 072192)
[e-mail]
David D. Yang (SBN 263949)
[e-mail]
800 W. 6th Street, Suite 500
Los Angeles, California 90017
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
LEWIS BRISBOIS BISGAARD & SMITH
LLP

16

UNITED STATES DISTRICT COURT

17

CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

18
19
20

NELSON LEVINE DE LUCA &
HAMILTON, LLC,

STIPULATED PROTECTIVE ORDER

Plaintiff,

21

Case No. 14-CV-03994 FMO-SHx

DISCOVERY MATTER

22

v.

23

LEWIS BRISBOIS BISGAARD &
SMITH LLP,

24

Defendant.

25
26
27
28
1
STIPULATED PROTECTIVE ORDER

1
2

1.

A.

PURPOSES AND LIMITATIONS

Discovery in this action is likely to involve production/disclosure of

3

confidential, proprietary, and/or private information, in the form of document

4

productions, discovery responses, and/or deposition testimony, for which

5

special protection from unnecessary public disclosure and from use for any

6

purpose other than prosecuting this litigation may be warranted. Accordingly,

7

the parties hereby stipulate to and petition the Court to enter the following

8

Stipulated Protective Order. The parties acknowledge that this Order does not

9

confer blanket protections on all disclosures or responses to discovery and that
the protection it affords from public disclosure and use extends only to the

11
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

10

limited information or items that are entitled to confidential treatment under the

12

applicable legal principles.

13

B.

GOOD CAUSE STATEMENT

14

This action is likely to involve attorney-client communications, personal

15

identifiable information, trade secrets, and other valuable research,

16

development, commercial, financial, technical and/or proprietary information

17

for which special protection from unnecessary public disclosure and from use

18

for any purpose other than prosecution of this action is warranted. Such

19

confidential and proprietary materials and information may consist of, among

20

other things, confidential business or financial information, information

21

regarding confidential business practices, or other confidential research,

22

development, or commercial information (including information implicating

23

privacy rights of third parties), information otherwise generally unavailable to

24

the public, or which may be privileged or otherwise protected from disclosure

25

under state or federal statutes, court rules, case decisions, or common law.

26

Accordingly, to expedite the flow of information, to facilitate the prompt

27

resolution of disputes over confidentiality of discovery materials, to adequately

28

protect information the parties are entitled to keep confidential, to ensure that
2
STIPULATED PROTECTIVE ORDER

1

the parties are permitted reasonable necessary uses of such material in

2

preparation for and in the conduct of trial, to address their handling at the end

3

of the litigation, and serve the ends of justice, a protective order for such

4

information is justified in this matter. It is the intent of the parties that

5

information will not be designated as confidential for tactical reasons and that

6

nothing be so designated without a good faith belief that it has been maintained

7

in a confidential, non-public manner.

8

2.

DEFINITIONS
2.1

9

Action: The instant federal lawsuit entitled Nelson Levine de Luca

Hamilton, LLC v. Lewis Brisbois Bisgaard & Smith, LLP, et al., United States

11
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

10

District Court, Central District of California, Case No. 14-CV-03994 FMO-

12

SHx.

13
14
15

2.2

Challenging Party: a Party or Non-Party that challenges the

designation of information or items under this Order.
2.3

“CONFIDENTIAL” Information or Items: information (regardless

16

of how it is generated, stored or maintained) or tangible things, that may be

17

disclosed in the form of document productions, discovery responses, and/or

18

deposition testimony, and that qualify for protection under Federal Rule of

19

Civil Procedure 26(c) and as specified above in the Good Cause Statement.

20
21
22

2.4

Counsel: Outside Counsel of Record and House Counsel (as well as

their support staff).
2.5

Designating Party: a Party or Non-Party that designates information

23

or items that it produces in disclosures or in responses to discovery as

24

“CONFIDENTIAL.”

25

2.6

Disclosure or Discovery Material: all items or information,

26

regardless of the medium or manner in which it is generated, stored, or

27

maintained (including, among other things, testimony, transcripts, and tangible

28
3
STIPULATED PROTECTIVE ORDER

1

things), that are produced or generated in disclosures or responses to discovery

2

in this matter.
2.7

3

Expert: a person with specialized knowledge or experience in a

4

matter pertinent to the litigation who has been retained by a Party or its counsel

5

to serve as an expert witness or as a consultant in this Action.
2.8

6

House Counsel: attorneys who are employees of a party to this

7

Action. House Counsel does not include Outside Counsel of Record or any

8

other outside counsel.
2.9

9
10

association, or other legal entity not named as a Party to this action.
2.10 Outside Counsel of Record: attorneys who are not employees of a

11
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

Non-Party: any natural person, partnership, corporation,

12

party to this Action but are retained to represent or advise a party to this Action

13

and have appeared in this Action on behalf of that party or are affiliated with a

14

law firm which has appeared on behalf of that party, and includes support staff.
2.11 Party: any party to this Action, including all of its officers,

15
16

directors, employees, consultants, retained experts, and Outside Counsel of

17

Record (and their support staffs).
2.12 Producing Party: a Party or Non-Party that produces Disclosure or

18
19

Discovery Material in this Action.
2.13 Professional Vendors: persons or entities that provide litigation

20
21

support services (e.g., photocopying, videotaping, translating, preparing

22

exhibits or demonstrations, and organizing, storing, or retrieving data in any

23

form or medium) and their employees and subcontractors.
2.14 Protected Material: any Disclosure or Discovery Material that is

24
25

designated as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery

26
27

Material from a Producing Party.

28

///
4
STIPULATED PROTECTIVE ORDER

1

3.

SCOPE

2

The protections conferred by this Stipulation and Order cover not only

3

Protected Material (as defined above), but also (1) any information copied or

4

extracted from Protected Material; (2) all copies, excerpts, summaries, or

5

compilations of Protected Material; and (3) any testimony, conversations, or

6

presentations by Parties or their Counsel that might reveal Protected Material.

7

Any use of Protected Material at trial shall be governed by the orders of

8

the trial judge. This Order does not govern the use of Protected Material at trial.

9

4.

DURATION
Even after final disposition of this litigation, the confidentiality

11
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

10

obligations imposed by this Order shall remain in effect until a Designating

12

Party agrees otherwise in writing or a court order otherwise directs.
Final disposition shall be deemed to be the later of (1) dismissal of all

13
14

claims and defenses in this Action, with or without prejudice; and (2) final

15

judgment herein after the completion and exhaustion of all appeals, rehearings,

16

remands, trials, or reviews of this Action, including the time limits for filing

17

any motions or applications for extension of time pursuant to applicable law.

18

5.

19

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for

20

Protection. Each Party or Non-Party that designates information or items for

21

protection under this Order must take care to limit any such designation to

22

specific material that qualifies under the appropriate standards. The Designating

23

Party must designate for protection only those parts of material, documents,

24

items, or oral or written communications that qualify so that other portions of

25

the material, documents, items, or communications for which protection is not

26

warranted are not swept unjustifiably within the ambit of this Order.

27
28

Mass, indiscriminate, or routinized designations are prohibited.
Designations that are shown to be clearly unjustified or that have been made for
5
STIPULATED PROTECTIVE ORDER

1

an improper purpose (e.g., to unnecessarily encumber the case development

2

process or to impose unnecessary expenses and burdens on other parties) may

3

expose the Designating Party to sanctions.

4

If it comes to a Designating Party’s attention that information or items

5

that it designated for protection do not qualify for protection, that Designating

6

Party must promptly notify all other Parties that it is withdrawing the

7

inapplicable designation.

8
9

5.2

Manner and Timing of Designations. Except as otherwise provided

in this Order (see, e.g., second paragraph of section 5.2(a) below), or as
otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies

11
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

10

for protection under this Order must be clearly so designated before the

12

material is disclosed or produced.

13

Designation in conformity with this Order requires:

14

(a) for information in documentary form (e.g., paper or electronic

15

documents, but excluding transcripts of depositions or other pretrial or trial

16

proceedings), that the Producing Party affix at a minimum, the legend

17

“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page

18

that contains protected material. If only a portion or portions of the material on

19

a page qualifies for protection, the Producing Party also must clearly identify

20

the protected portion(s) (e.g., by making appropriate markings in the margins).

21

A Party or Non-Party that makes original documents available for

22

inspection need not designate them for protection until after the inspecting

23

Party has indicated which documents it would like copied and produced.

24

During the inspection and before the designation, all of the material made

25

available for inspection shall be deemed “CONFIDENTIAL.” After the

26

inspecting Party has identified the documents it wants copied and produced, the

27

Producing Party must determine which documents, or portions thereof, qualify

28

for protection under this Order. Then, before producing the specified
6
STIPULATED PROTECTIVE ORDER

1

documents, the Producing Party must affix the “CONFIDENTIAL legend” to

2

each page that contains Protected Material. If only a portion or portions of the

3

material on a page qualifies for protection, the Producing Party also must

4

clearly identify the protected portion(s) (e.g., by making appropriate markings

5

in the margins).

6

(b)

for testimony given in depositions that the Designating Party

7

identify the Disclosure or Discovery Material on the record, before the close of

8

the deposition all protected testimony.
(c)

9

for information produced in some form other than documentary and

for any other tangible items, that the Producing Party affix in a prominent place

11
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

10

on the exterior of the container or containers in which the information is stored

12

the legend “CONFIDENTIAL.” If only a portion or portions of the information

13

warrants protection, the Producing Party, to the extent practicable, shall identify

14

the protected portion(s).
5.3

15

Inadvertent Failures to Designate. If timely corrected, an

16

inadvertent failure to designate qualified information or items does not,

17

standing alone, waive the Designating Party’s right to secure protection under

18

this Order for such material. Upon timely correction of a designation, the

19

Receiving Party must make reasonable efforts to assure that the material is

20

treated in accordance with the provisions of this Order.

21

6.

22

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Timing of Challenges. Any Party or Non-Party may challenge a

23

designation of confidentiality at any time that is consistent with the Court’s

24

Scheduling Order.

25

6.2

Meet and Confer. The Challenging Party shall initiate the dispute

26

resolution process under Local Rule 37-1, et seq. or, if necessary, under Local

27

Rule 6-1, and 7-1, et seq.

28
7
STIPULATED PROTECTIVE ORDER

6.3

1

The burden of persuasion in any such challenge proceeding shall be

2

on the Designating Party. Frivolous challenges, and those made for an improper

3

purpose (e.g., to harass or impose unnecessary expenses and burdens on other

4

parties) may expose the Challenging Party to sanctions. Unless the Designating

5

Party has waived or withdrawn the confidentiality designation, all parties shall

6

continue to afford the material in question the level of protection to which it is

7

entitled under the Producing Party’s designation until the Court rules on the

8

challenge.

9

7.

10

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material

B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

11

that is disclosed or produced by another Party or by a Non-Party in connection

12

with this Action only for prosecuting, defending, or attempting to settle this

13

Action, and for no other purpose. Such Protected Material may be disclosed

14

only to the categories of persons and under the conditions described in Section

15

7.2 of this Order (“Qualified Person” or “Qualified Persons”) . No Qualified

16

Person who gains access to the Protected Material may disclose the Protected

17

Material, or their contents, to any other person without the written stipulation of

18

the Producing Party or by order of this Court. The Protected Material may be

19

used at trial or at depositions in accordance with the following safeguards. If

20

Protected Information is used in deposition, all portions of the transcript of such

21

deposition or exhibits thereto which refer to or relate to such Protected

22

Information shall themselves by considered as Confidential Documents.

23

When the Action has been terminated, a Receiving Party must comply with the

24

provisions of section 13 below (FINAL DISPOSITION).

25

Protected Material must be stored and maintained by a Receiving Party at

26

a location and in a secure manner that ensures that access is limited to the

27

persons authorized under this Order.

28
8
STIPULATED PROTECTIVE ORDER

1

7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

2

otherwise ordered by the court or permitted in writing by the Designating Party,

3

a Receiving Party may disclose any information or item designated

4

“CONFIDENTIAL” only to:
(a)

5

the Receiving Party’s Outside Counsel of Record in this

6

Action, as well as employees of said Outside Counsel of Record to whom it is

7

reasonably necessary to disclose the information for this Action;
(b)

8
9
10
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

11

the officers, directors, and employees (including House

Counsel) of the Receiving Party to whom disclosure is reasonably necessary for
this Action;
(c)

Experts (as defined in this Order) of the Receiving Party to

12

whom disclosure is reasonably necessary for this Action and who have signed

13

the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

14

(d)

the Court and its personnel;

15

(e)

court reporters and their staff;

16

(f)

the jury;

17

(g)

professional jury or trial consultants, mock jurors, and

18

Professional Vendors to whom disclosure is reasonably necessary for this

19

Action and who have signed the “Acknowledgment and Agreement to Be

20

Bound” (Exhibit A);

21

(h)

the author or recipient of a document containing the

22

information or a custodian or other person who otherwise possessed or knew

23

the information;

24

(i)

during their depositions, witnesses and attorneys for

25

witnesses, in the Action to whom disclosure is reasonably necessary provided:

26

(1) the deposing party requests that the witness sign the form attached as

27

Exhibit 1 hereto; and (2) they will not be permitted to keep any confidential

28

information unless they sign the “Acknowledgment and Agreement to Be
9
STIPULATED PROTECTIVE ORDER

1

Bound” (Exhibit A), unless otherwise agreed by the Designating Party or

2

ordered by the court. Pages of transcribed deposition testimony or exhibits to

3

depositions that reveal Protected Material may be separately bound by the court

4

reporter and may not be disclosed to anyone except as permitted under this

5

Stipulated Protective Order; and
(j)

6

any mediator or settlement officer, and their supporting

7

personnel, mutually agreed upon by any of the parties engaged in settlement

8

discussions.

9

8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED IN OTHER LITIGATION

11
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

10

If a Party is served with a subpoena or a court order issued in other

12

litigation that compels disclosure of any information or items designated in this

13

Action as “CONFIDENTIAL,” that Party must:

14
15
16

(a)

promptly notify in writing the Designating Party. Such notification

shall include a copy of the subpoena or court order;
(b)

promptly notify in writing the party who caused the subpoena or

17

order to issue in the other litigation that some or all of the material covered by

18

the ; subpoena or order is subject to this Protective Order. Such notification

19

shall include a copy of this Stipulated Protective Order; and

20
21

(c)

cooperate with respect to all reasonable procedures sought to be

pursued by the Designating Party whose Protected Material may be affected.

22

If the Designating Party timely seeks a protective order, the Party served

23

with the subpoena or court order shall not produce any information designated

24

in this action as “CONFIDENTIAL” before a determination by the court from

25

which the subpoena or order issued, unless the Party has obtained the

26

Designating Party’s permission. The Designating Party shall bear the burden

27

and expense of seeking protection in that court of its confidential material and

28
10
STIPULATED PROTECTIVE ORDER

1

nothing in these provisions should be construed as authorizing or encouraging a

2

Receiving Party in this Action to disobey a lawful directive from another court.

3

9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

4

PRODUCED IN THIS LITIGATION

5

(a)

The terms of this Order are applicable to information produced by a

6

Non-Party in this Action and designated as “CONFIDENTIAL.” Such

7

information produced by Non-Parties in connection with this litigation is

8

protected by the remedies and relief provided by this Order. Nothing in these

9

provisions should be construed as prohibiting a Non-Party from seeking

10
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

11

additional protections.
(b)

In the event that a Party is required, by a valid discovery request, to

12

produce a Non-Party’s confidential information in its possession, and the Party

13

is subject to an agreement with the Non-Party not to produce the Non-Party’s

14

confidential information, then the Party shall:
(1)

15

promptly notify in writing the Requesting Party and the Non-

16

Party that some or all of the information requested is subject to a confidentiality

17

agreement with a Non-Party;
(2)

18

promptly provide the Non-Party with a copy of the Stipulated

19

Protective Order in this Action, the relevant discovery request(s), and a

20

reasonably specific description of the information requested; and

21

(3)

22

the Non-Party, if requested.

23

(c)

make the information requested available for inspection by

If the Non-Party fails to seek a protective order from this court

24

within 14 days of receiving the notice and accompanying information, the

25

Receiving Party may produce the Non-Party’s confidential information

26

responsive to the discovery request. If the Non-Party timely seeks a protective

27

order, the Receiving Party shall not produce any information in its possession

28

or control that is subject to the confidentiality agreement with the Non-Party
11
STIPULATED PROTECTIVE ORDER

1

before a determination by the court. Absent a court order to the contrary, the

2

Non-Party shall bear the burden and expense of seeking protection in this court

3

of its Protected Material.

4

10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has

5

disclosed Protected Material to any person or in any circumstance not

7

authorized under this Stipulated Protective Order, the Receiving Party must

8

immediately (a) notify in writing the Designating Party of the unauthorized

9

disclosures, (b) use its best efforts to retrieve all unauthorized copies of the

10

Protected Material, (c) inform the person or persons to whom unauthorized

11
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

6

disclosures were made of all the terms of this Order, and (d) request such

12

person or persons to execute the “Acknowledgment and Agreement to Be

13

Bound” that is attached hereto as Exhibit A.

14

11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
When a Producing Party gives notice to Receiving Parties that certain

15
16

inadvertently produced material is subject to a claim of privilege or other

17

protection, the obligations of the Receiving Parties are those set forth in Federal

18

Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

19

whatever procedure may be established in an e-discovery order that provides

20

for production without prior privilege review. Pursuant to Federal Rule of

21

Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect

22

of disclosure of a communication or information covered by the attorney-client

23

privilege or work product protection, the parties may incorporate their

24

agreement in the stipulated protective order submitted to the court.

25

12.

26
27

MISCELLANEOUS
12.1 Right to Further Relief. Nothing in this Order abridges the right of

any person to seek its modification by the Court in the future.

28
12
STIPULATED PROTECTIVE ORDER

1

12.2 Right to Assert Other Objections. By stipulating to the entry of this

2

Protective Order no Party waives any right it otherwise would have to object to

3

disclosing or producing any information or item on any ground not addressed in

4

this Stipulated Protective Order. Similarly, no Party waives any right to object

5

on any ground to use in evidence of any of the material covered by this

6

Protective Order.

7

12.3 Filing Protected Material. Nothing in this Order shall prohibit

8

either Party to file with the Court and/or present as evidence any Protected

9

Material as part of any motion or hearing. Any such use of Protected Material
shall not be considered violative of this Order.

11
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

10

13.

12

FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4,

13

within 60 days of a written request by the Designating Party, each Receiving

14

Party must return all Protected Material to the Producing Party or destroy such

15

material. As used in this subdivision, all Protected Material” includes all copies,

16

abstracts, compilations, summaries, and any other format reproducing or

17

capturing any of the Protected Material. Whether the Protected Material is

18

returned or destroyed, the Receiving Party must submit a written certification to

19

the Producing Party (and, if not the same person or entity, to the Designating

20

Party) by the 60 day deadline that (1) identifies (by category, where

21

appropriate) all the Protected Material that was returned or destroyed and

22

(2)affirms that the Receiving Party has not retained any copies, abstracts,

23

compilations, summaries or any other format reproducing or capturing any of

24

the Protected Material. Notwithstanding this provision, Counsel are entitled to

25

retain an archival copy of all pleadings, motion papers, trial, deposition, and

26

hearing transcripts, legal memoranda, correspondence, deposition and trial

27

exhibits, expert reports, attorney work product, and consultant and expert work

28

product, even if such materials contain Protected Material. Any such archival
13
STIPULATED PROTECTIVE ORDER

1

copies that contain or constitute Protected Material remain subject to this

2

Protective Order as set forth in Section 4 (DURATION).

3

14.

4

measures including, without limitation, contempt proceedings and/or monetary

5

sanctions.

6

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

7

DATED: March 13, 2015

Any violation of this Order may be punished by any and all appropriate

BAKER & HOSTETLER LLP

8
9

By:

10
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

11
12

DATED: March 13, 2015

/s/ Robert C. Welsh
Robert C. Welsh
Attorneys for Plaintiff
NELSON LEVINE DE LUCA &
HAMILTON, LLC

PARKER MILLS LLP

13

By:

14
15
16

/s/ David D. Yang
David B. Parker
David D. Yang
Attorneys for Defendant
LEWIS BRISBOIS BISGAARD &
SMITH LLP

17
18
19
20
21
22
23
24
25

ATTESTATION OF E-SIGNATURES RE: L.R. 5-4.3.4

I, David D. Yang, attest that all signatories listed, and whose behalf the filing
is submitted, concur in the filings content and have authorized the filing.
DATED: March 13, 2015

PARKER MILLS LLP
By:

/s/ David D. Yang
David D. Yang
Attorneys for Defendant
LEWIS BRISBOIS BISGAARD &
SMITH LLP

26
27
28
14
STIPULATED PROTECTIVE ORDER

1

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

2
3

DATED:

March 16, 2015

4
5
6
7

Hon. Stephen J. Hillman
United States Magistrate Judge

8
9
10
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
15
STIPULATED PROTECTIVE ORDER

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3
4
5
6
7
8
9
10
B AKER & H OSTETLER LLP
A TTORNEYS AT L A W
L OS A NGELES

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

I, _______________________________ [print or type full name], of
______________________________[print or type full address], declare under
penalty of perjury that I have read in its entirety and understand the Stipulated
Protective Order that was issued by the United States District Court for the Central
District of California on ______________[date] in the case entitled Nelson Levine de
Luca Hamilton, LLC v. Lewis Brisbois Bisgaard & Smith, LLP, et al., filed in the United
States District Court, Central District of California, Case No. 14-CV-03994 FMO-SHx.
I agree to comply with and to be bound by all the terms of this Stipulated Protective
Order and I understand and acknowledge that failure to so comply could expose me
to sanctions and punishment in the nature of contempt. I solemnly promise that I will
not disclose in any manner any information or item that is subject to this Stipulated
Protective Order to any person or entity except in strict compliance with the
provisions of this Order. I further agree to submit to the jurisdiction of the United
States District Court for the Central District of California for the purpose of
enforcing the terms of this Stipulated Protective Order, even if such enforcement
proceedings occur after termination of this action. I hereby appoint
____________________________ [print or type full name] of
____________________________________ [print or type full address and telephone
number] as my California agent for service of process in connection with this action
or any proceedings related to enforcement of this Stipulated Protective Order.
Date:
City and State where sworn and signed:
Printed name:

26
27

Signature:

28
16
STIPULATED PROTECTIVE ORDER