California Communities Against Toxics v. Armorcast Products Company, Inc.

Filing 77

PROTECTIVE ORDER RE INITIAL RULE 34 INSPECTION OF ARMORCAST PRODUCTS COMPANY, INC.S FACILITY 73 by Magistrate Judge Frederick F. Mumm. *Note: Changes Made by the Court.* (Attachments: # 1 Attachment) (es)

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AGREEMENT TO BE BOUND BY TERMS OF PROTECTIVE ORDER
I hereby acknowledge that I have received a copy of the Stipulation for Entry
of Protective Order Re: Rule 34 Inspections of Armorcast Products Company, Inc.’s
(“Armocast”) Facility in the action entitled California Communities Against Toxics v.
Armorcast Products Company, Inc. et al (United States District Court, Central

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District of California, Case No. 2:14-cv-05728-PA-FFMx). I have carefully read and

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I fully understand the terms of the Stipulation. I recognize that I am bound by the

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terms of the Stipulation and any Protective Order issued pursuant thereto, and I agree
to comply with those terms. I agree, under penalty of perjury, not to disclose
photographs designated in the Stipulation and any Protective Order issued pursuant

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thereto.
I hereby consent to the subject matter and personal jurisdiction of this court in

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respect to any proceedings relative to the enforcement of the Protective Order

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regarding Rule 34 Inspections of Armorcast’s Facility, including, without limitation,

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any proceeding related to contempt of court.
At the end of this litigation or my involvement in this litigation, whichever
occurs first, I will return to counsel for the party by whom I am employed or retained,

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all such photographs of Armorcast’s facility (including originals and all copies

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thereof).

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This agreement shall be subject to the terms of the Protective Order and shall
STIPULATION FOR PROTECTIVE ORDER

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Case No. 2:14-cv-05728-PA-FFMx

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be governed by the laws of the State of California.

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Name: _____________________________
Signature: __________________________
Date: ______________________

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STIPULATION FOR PROTECTIVE ORDER

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Case No. 2:14-cv-05728-PA-FFMx