Arnold Saulsberry v. Meridian Financial Services, Inc.
Filing
21
STIPULATED PROTECTIVE ORDER by Magistrate Judge Jean P. Rosenbluth re Stipulation for Protective Order 17 . (See Order for details)[NOTE: CHANGES MADE B Y THE COURT] (bem)
6
Mark E. Ellis - 127159
Andrew M. Steinheimer - 200524
Ephraim Egan - 278122
ELLIS LAW GROUP LLP
740 University Avenue, Suite 100
Sacramento, CA 95825
Tel: (916) 283-8820
Fax: (916) 283-8821
mellis@ellislawgrp.com
asteinheimer@ellislawgrp.com
eegan@ellislawgrp.com
7
Attorneys for Defendant MERIDIAN FINANCIAL SERVICES, INC.
1
2
3
4
5
NOTE: CHANG ES M ADE BY THE CO URT
8
9
UNITED STATES DISTRICT COURT
10
CENTRAL DISTRICT OF CALIFORNIA
ARNOLD SAULSBERRY, individually
and on behalf of all others similarly
12 situated,
11
STIPULATED PROTECTIVE ORDER
Plaintiff,
13
14
Case No.: 2:14-cv-06256-MMM-SH
v.
MERIDIAN FINANCIAL SERVICES,
INC., and DOES 1 through 10, inclusive,
16 and each of them,
15
Defendants.
17
18
19
1.
PURPOSES AND LIMITATIONS
20
Disclosure and discovery activity in this action are likely to involve production of
21
confidential, proprietary, or private information for which special protection from public
22
disclosure and from use for any purpose other than prosecuting this litigation may be
23
warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the
24
following Stipulated Protective Order. The parties acknowledge that this Order does not
25
confer blanket protections on all disclosures or responses to discovery and that the
26
protection it affords from public disclosure and use extends only to the limited
27
information or items that are entitled to confidential treatment under the applicable legal
28
principles. The parties further acknowledge, as set forth in Section 12.3, below, that this
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STIPULATED PROTECTIVE ORDER
1
Stipulated Protective Order does not entitle them to file confidential information under
2
seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the
3
standards that will be applied when a party seeks permission from the court to file
4
material under seal.
5
2.
2.1
6
7
10
2.2
“CONFIDENTIAL” Information or Items: information (regardless of how
it is generated, stored or maintained) or tangible things that qualify for protection under
Federal Rule of Civil Procedure 26(c).
2.3
11
12
Challenging Party: a Party or Non-Party that challenges the designation of
information or items under this Order.
8
9
DEFINITIONS
Counsel (without qualifier):
Outside Counsel of Record and House
Counsel (as well as their support staff).
2.4
13
14
items
15
“CONFIDENTIAL.”
16
that
Designating Party: a Party or Non-Party that designates information or
2.5
it
produces
in
disclosures
or
in
responses
to
discovery
as
Disclosure or Discovery Material: all items or information, regardless of
17
the medium or manner in which it is generated, stored, or maintained (including, among
18
other things, testimony, transcripts, and tangible things), that are produced or generated
19
in disclosures or responses to discovery in this matter.
20
2.6
Expert: a person with specialized knowledge or experience in a matter
21
pertinent to the litigation who has been retained by a Party or its counsel to serve as an
22
expert witness or as a consultant in this action.
23
2.7
House Counsel: attorneys who are employees of a party to this action.
24
House Counsel does not include Outside Counsel of Record or any other outside
25
counsel.
26
27
2.8
Non-Party: any natural person, partnership, corporation, association, or
other legal entity not named as a Party to this action.
28
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STIPULATED PROTECTIVE ORDER
2.9
1
Outside Counsel of Record: attorneys who are not employees of a party to
2
this action but are retained to represent or advise a party to this action and have
3
appeared in this action on behalf of that party or are affiliated with a law firm which has
4
appeared on behalf of that party.
5
2.10 Party: any party to this action, including all of its officers, directors,
6
employees, consultants, retained experts, and Outside Counsel of Record (and their
7
support staffs).
2.11 Producing Party:
8
9
a Party or Non-Party that produces Disclosure or
Discovery Material in this action.
2.12 Professional Vendors: persons or entities that provide litigation support
10
11
services
12
demonstrations, and organizing, storing, or retrieving data in any form or medium) and
13
their employees and subcontractors.
photocopying,
2.13 Protected Material:
14
15
(e.g.,
videotaping,
translating,
preparing
exhibits
or
any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL.”
2.14 Receiving Party: a Party that receives Disclosure or Discovery Material
16
17
from a Producing Party.
18
3.
SCOPE
19
The protections conferred by this Stipulation and Order cover not only Protected
20
Material (as defined above), but also (1) any information copied or extracted from
21
Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
22
Material; and (3) any testimony, conversations, or presentations by Parties or their
23
Counsel that might reveal Protected Material. However, the protections conferred by
24
this Stipulation and Order do not cover the following information: (a) any information
25
that is in the public domain at the time of disclosure to a Receiving Party or becomes
26
part of the public domain after its disclosure to a Receiving Party as a result of
27
publication not involving a violation of this Order, including becoming part of the
28
public record through trial or otherwise; and (b) any information known to the
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STIPULATED PROTECTIVE ORDER
1
Receiving Party prior to the disclosure or obtained by the Receiving Party after the
2
disclosure from a source who obtained the information lawfully and under no obligation
3
of confidentiality to the Designating Party. Any use of Protected Material at trial shall
4
be governed by a separate agreement or order.
5
4.
DURATION
6
Even after final disposition of this litigation, the confidentiality obligations
7
imposed by this Order shall remain in effect until a Designating Party agrees otherwise
8
in writing or a court order otherwise directs. Final disposition shall be deemed to be the
9
later of (1) dismissal of all claims and defenses in this action, with or without prejudice;
10
and (2) final judgment herein after the completion and exhaustion of all appeals,
11
rehearings, remands, trials, or reviews of this action, including the time
12
limits for filing any motions or applications for extension of time pursuant to applicable
13
law.
14
5.
DESIGNATING PROTECTED MATERIAL
5.1
15
Exercise of Restraint and Care in Designating Material for Protection. Each
16
Party or Non-Party that designates information or items for protection under this Order
17
must take care to limit any such designation to specific material that qualifies under the
18
appropriate standards. The Designating Party must designate for protection only those
19
parts of material, documents, items, or oral or written communications that qualify – so
20
that other portions of the material, documents, items, or communications for which
21
protection is not warranted are not swept unjustifiably within the ambit of this Order.
22
Mass, indiscriminate, or routinized designations are prohibited. Designations that
23
are shown to be clearly unjustified or that have been made for an improper purpose
24
(e.g., to unnecessarily encumber or retard the case development process or to impose
25
unnecessary expenses and burdens on other parties) expose the Designating Party to
26
sanctions.
27
////
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////
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STIPULATED PROTECTIVE ORDER
1
If it comes to a Designating Party’s attention that information or items that it
2
designated for protection do not qualify for protection, that Designating Party must
3
promptly notify all other Parties that it is withdrawing the mistaken designation.
4
5.2
Manner and Timing of Designations. Except as otherwise provided in this
5
Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
6
ordered, Disclosure or Discovery Material that qualifies for protection under this Order
7
must be clearly so designated before the material is disclosed or produced.
8
Designation in conformity with this Order requires:
9
(a) for information in documentary form (e.g., paper or electronic documents,
10
but excluding transcripts of depositions or other pretrial or trial proceedings), that the
11
Producing Party affix the legend “CONFIDENTIAL” to each page that contains
12
protected material. If only a portion or portions of the material on a page qualifies for
13
protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,
14
by making appropriate markings in the margins).
15
A Party or Non-Party that makes original documents or materials available for
16
inspection need not designate them for protection until after the inspecting Party has
17
indicated which material it would like copied and produced. During the inspection and
18
before the designation, all of the material made available for inspection shall be deemed
19
“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
20
copied and produced, the Producing Party must determine which documents, or portions
21
thereof, qualify for protection under this Order. Then, before producing the specified
22
documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page
23
that contains Protected Material. If only a portion or portions of the material on a page
24
qualifies for protection, the Producing Party also must clearly identify the protected
25
portion(s) (e.g., by making appropriate markings in the margins).
26
(b)
for testimony given in deposition or in other discovery-related
27
proceedings, that the Designating Party identify on the record, before the close of the
28
deposition, hearing, or other proceeding, all protected testimony.
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STIPULATED PROTECTIVE ORDER
1
(c) for information produced in some form other than documentary and for
2
any other tangible items, that the Producing Party affix in a prominent place on the
3
exterior of the container or containers in which the information or item is stored the
4
legend “CONFIDENTIAL.” If only a portion or portions of the information or item
5
warrant protection, the Producing Party, to the extent practicable, shall identify the
6
protected portion(s).
5.3
7
Inadvertent Failures to Designate.
If timely corrected, an inadvertent
8
failure to designate qualified information or items does not, standing alone, waive the
9
Designating Party’s right to secure protection under this Order for such material. Upon
10
timely correction of a designation, the Receiving Party must make reasonable efforts to
11
assure that the material is treated in accordance with the provisions of this Order.
12
6.
13
CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
Timing of Challenges.
Any Party or Non-Party may challenge a
14
designation of confidentiality at any time. Unless a prompt challenge to a Designating
15
Party’s confidentiality designation is necessary to avoid foreseeable, substantial
16
unfairness, unnecessary economic burdens, or a significant disruption or delay of the
17
litigation, a Party does not waive its right to challenge a confidentiality designation by
18
electing not to mount a challenge promptly after the original designation is disclosed.
19
6.2
Meet and Confer.
The Challenging Party shall initiate the dispute
20
resolution process by providing written notice of each designation it is challenging and
21
describing the basis for each challenge. To avoid ambiguity as to whether a challenge
22
has been made, the written notice must recite that the challenge to confidentiality is
23
being made in accordance with this specific paragraph of the Protective Order. The
24
parties shall attempt to resolve each challenge in good faith and must begin the process
25
by conferring directly (in voice to voice dialogue; other forms of communication are not
26
sufficient) within 10 days of the date of service of notice. In conferring, the Challenging
27
Party must explain the basis for its belief that the confidentiality designation was not
28
proper and must give the Designating Party an opportunity to review the designated
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STIPULATED PROTECTIVE ORDER
1
material, to reconsider the circumstances, and, if no change in designation is offered, to
2
explain the basis for the chosen designation. A Challenging Party may proceed to the
3
next stage of the challenge process only if it has engaged in this meet and confer process
4
first or establishes that the Designating Party is unwilling to participate in the meet and
5
confer process in a timely manner.
6
6.3
Judicial Intervention. If the Parties cannot resolve a challenge without
7
court intervention, the Designating Party shall file and serve a motion to retain
8
confidentiality under Civil Local Rule 37 (and in compliance with Civil Local Rule 79-
9
5, if applicable) within 21 days of the initial notice of challenge or within 14 days of the
10
parties agreeing that the meet and confer process will not resolve their dispute,
11
whichever is earlier. Each such motion must be accompanied by a competent
12
declaration affirming that the movant has complied with the meet and confer
13
requirements imposed in the preceding paragraph. Failure by the Designating Party to
14
make such a motion including the required declaration within 21 days (or 14 days, if
15
applicable) shall automatically waive the confidentiality designation for each challenged
16
designation. In addition, the Challenging Party may file a motion challenging a
17
confidentiality designation at any time if there is good cause for doing so, including a
18
challenge to the designation of a deposition transcript or any portions thereof. Any
19
motion brought pursuant to this provision must be accompanied by a competent
20
declaration affirming that the movant has complied with the meet and confer
21
requirements imposed by the preceding paragraph.
22
The burden of persuasion in any such challenge proceeding shall be on the
23
Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
24
to harass or impose unnecessary expenses and burdens on other parties) may expose the
25
Challenging Party to sanctions. Unless the Designating Party has waived the
26
confidentiality designation by failing to file a motion to retain confidentiality as
27
described above, all parties shall continue to afford the material in question the level of
28
protection to which it is entitled under the Producing Party’s designation until the court
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STIPULATED PROTECTIVE ORDER
1
rules on the challenge.
2
7.
3
ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is
4
disclosed or produced by another Party or by a Non-Party in connection with this case
5
only for prosecuting, defending, or attempting to settle this litigation. Such Protected
6
Material may be disclosed only to the categories of persons and under the conditions
7
described in this Order. When the litigation has been terminated, a Receiving Party must
8
comply with the provisions of section 13 below (FINAL DISPOSITION).
9
Protected Material must be stored and maintained by a Receiving Party at a
10
location and in a secure manner that ensures that access is limited to the persons
11
authorized under this Order.
12
7.2
Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
13
ordered by the court or permitted in writing by the Designating Party, a Receiving Party
14
may disclose any information or item designated “CONFIDENTIAL” only to:
15
(a) the Receiving Party’s Outside Counsel of Record in this action, as well as
16
employees of said Outside Counsel of Record to whom it is reasonably necessary to
17
disclose the information for this litigation and who have signed the “Acknowledgment
18
and Agreement to Be Bound” that is attached hereto as Exhibit A;
19
(b) the officers, directors, and employees (including House Counsel) of the
20
Receiving Party to whom disclosure is reasonably necessary for this litigation and who
21
have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
22
(c)
Experts (as defined in this Order) of the Receiving Party to whom
23
disclosure is reasonably necessary for this litigation and who have signed the
24
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
25
(d) the court and its personnel;
26
(e) court reporters and their staff, professional jury or trial consultants, mock
27
jurors, and Professional Vendors to whom disclosure is reasonably necessary for this
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STIPULATED PROTECTIVE ORDER
1
litigation and who have signed the “Acknowledgment and Agreement to Be Bound”
2
(Exhibit A);
3
(f) during their depositions, witnesses in the action to whom disclosure is
4
reasonably necessary and who have signed the “Acknowledgment and Agreement to Be
5
Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the
6
court. Pages of transcribed deposition testimony or exhibits to depositions that reveal
7
Protected Material must be separately bound by the court reporter and may not be
8
disclosed to anyone except as permitted under this Stipulated Protective Order.
(g) the author or recipient of a document containing the information or a
9
10
custodian or other person who otherwise possessed or knew the information.
11
8.
12
OTHER LITIGATION
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
13
If a Party is served with a subpoena or a court order issued in other litigation that
14
compels disclosure of any information or items designated in this action as
15
“CONFIDENTIAL,” that Party must:
16
17
(a) promptly notify in writing the Designating Party. Such notification shall
include a copy of the subpoena or court order;
18
(b) promptly notify in writing the party who caused the subpoena or order to
19
issue in the other litigation that some or all of the material covered by the subpoena or
20
order is subject to this Protective Order. Such notification shall include a copy of this
21
Stipulated Protective Order; and
22
23
(c) cooperate with respect to all reasonable procedures sought to be pursued
by the Designating Party whose Protected Material may be affected.
24
If the Designating Party timely seeks a protective order, the Party served with the
25
subpoena or court order shall not produce any information designated in this action as
26
“CONFIDENTIAL” before a determination by the court from which the subpoena or
27
order issued, unless the Party has obtained the Designating Party’s permission. The
28
Designating Party shall bear the burden and expense of seeking protection in that court
-9______________________________________________________________________________________________________________________________________________________________________________________________________________________
STIPULATED PROTECTIVE ORDER
1
of its confidential material – and nothing in these provisions should be construed as
2
authorizing or encouraging a Receiving Party in this action to disobey a lawful directive
3
from another court.
4
9.
5
IN THIS LITIGATION
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
6
(a) The terms of this Order are applicable to information produced by a Non-
7
Party in this action and designated as “CONFIDENTIAL.” Such information produced
8
by Non-Parties in connection with this litigation is protected by the remedies and relief
9
provided by this Order. Nothing in these provisions should be construed as prohibiting a
10
Non-Party from seeking additional protections.
11
(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 is
13
subject to an agreement with the Non-Party not to produce the Non-Party’s confidential
14
information, then the Party shall:
15
(1) promptly notify in writing the Requesting Party and the Non-Party that
16
some or all of the information requested is subject to a confidentiality agreement with a
17
Non-Party;
(2)
18
promptly provide the Non-Party with a copy of the Stipulated
19
Protective Order in this litigation, the relevant discovery request(s), and a reasonably
20
specific description of the information requested; and
(3) make the information requested available for inspection by the Non-
21
22
Party.
23
(c) If the Non-Party fails to object or seek a protective order from this court
24
within 14 days of receiving the notice and accompanying information, the Receiving
25
Party may produce the Non-Party’s confidential information responsive to the discovery
26
request. If the Non-Party timely seeks a protective order, the Receiving Party shall not
27
produce any information in its possession or control that is subject to the confidentiality
28
agreement with the Non-Party before a determination by the court. Absent a court order
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STIPULATED PROTECTIVE ORDER
1
to the contrary, the Non-Party shall bear the burden and expense of seeking protection in
2
this court of its Protected Material.
3
10.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
4
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
5
Protected Material to any person or in any circumstance not authorized under this
6
Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
7
the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
8
all unauthorized copies of the Protected Material, (c) inform the person or persons to
9
whom unauthorized disclosures were made of all the terms of this Order, and (d) request
10
such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
11
that is attached hereto as Exhibit A.
12
11.
13
PROTECTED
INADVERTENT
PRODUCTION
OF
PRIVILEGED
OR
OTHERWISE
MATERIAL
14
When a Producing Party gives notice to Receiving Parties that certain
15
inadvertently produced material is subject to a claim of privilege or other protection, the
16
obligations of the Receiving Parties are those set forth in Federal Rule of Civil
17
Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
18
may be established in an e-discovery order that provides for production without prior
19
privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
20
parties reach an agreement on the effect of disclosure of a communication or
21
information covered by the attorney-client privilege or work product protection, the
22
parties may incorporate their agreement in the stipulated protective order submitted to
23
the court.
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12.
25
26
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.
27
12.2 Right to Assert Other Objections. By stipulating to the entry of this
28
Protective Order no Party waives any right it otherwise would have to object to
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STIPULATED PROTECTIVE ORDER
1
disclosing or producing any information or item on any ground not addressed in this
2
Stipulated Protective Order. Similarly, no Party waives any right to object on any
3
ground to use in evidence of any of the material covered by this Protective Order.
4
12.3 Filing Protected Material. Without written permission from the Designating
5
Party or a court order secured after appropriate notice to all interested persons, a Party
6
may not file in the public record in this action any Protected Material. A Party that seeks
7
to file under seal any Protected Material must comply with Civil Local Rule 79-5.
8
Protected Material may only be filed under seal pursuant to a court order authorizing the
9
sealing of the specific Protected Material at issue. Pursuant to Civil Local Rule 79-5, a
10
sealing order will issue only upon a request establishing that the Protected Material at
11
issue is privileged, protectable as a trade secret, or otherwise entitled to protection under
12
the law.
13
13.
FINAL DISPOSITION
14
Within 60 days after the final disposition of this action, as defined in paragraph 4,
15
each Receiving Party must return all Protected Material to the Producing Party or
16
destroy such material. As used in this subdivision, “all Protected Material” includes all
17
copies, abstracts, compilations, summaries, and any other format reproducing or
18
capturing any of the Protected Material. Whether the Protected Material is returned or
19
destroyed, the Receiving Party must submit a written certification to the Producing
20
Party (and, if not the same person or entity, to the Designating Party) by the 60 day
21
deadline that (1) identifies (by category, where appropriate) all the Protected Material
22
that was returned or destroyed and (2) affirms that the Receiving Party has not retained
23
any copies, abstracts, compilations, summaries or any other format reproducing or
24
capturing any of the Protected Material. Notwithstanding this provision, Counsel are
25
entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and
26
hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits,
27
expert reports, attorney work product, and consultant and expert work product, even if
28
such materials contain Protected Material. Any such archival copies that contain or
- 12 ______________________________________________________________________________________________________________________________________________________________________________________________________________________
STIPULATED PROTECTIVE ORDER
1
constitute Protected Material remain subject to this Protective Order as set forth in
2
Section 4 (DURATION).
3
4
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
5
Dated: May 7, 2015
LAW OFFICES OF TODD M. FRIEDMAN,
P.C.
6
7
By /s/ Adrian R. Bacon
Adrian R. Bacon
Attorney for Plaintiff
ARNOLD SAULSBERRY
8
9
10
LAW OFFICES OF TODD M.
FRIEDMAN, P.C.
Adrian R. Bacon
324 S. Beverly Dr. #725
Beverly Hills, CA 90212
Telephone: (877) 206-4741
Facsimile: (866) 633-0228
abacon@attorneysforconsumers.com
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13
14
15
Dated: May 7, 2015
ELLIS LAW GROUP LLP
16
By /s/ Ephraim Egan
Ephraim Egan
Attorney for Defendant
MERIDIAN FINANCIAL SERVICES, INC.
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ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-4.3.4(a)(2)(i)
I, Ephraim Egan, hereby attest that the concurrence in the filing of this document
22
has been obtained from Adrian R. Bacon, counsel for Plaintiff Arnold Saulsberry. I
23
declare under penalty of perjury under the laws of the United States of America that the
24
foregoing is true and correct.
25
Executed this 17th day of April 2015.
26
27
/s/ Ephraim Egan
Ephraim Egan
28
- 13 ______________________________________________________________________________________________________________________________________________________________________________________________________________________
STIPULATED PROTECTIVE ORDER
1
PURSUANT TO STIPULATION, IT IS SO ORDERED.
2
3
4
DATED: May 6, 2015
____________________________________
JEAN P. ROSENBLUTH
UNITED STATES MAGISTRATE JUDGE
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- 14 ______________________________________________________________________________________________________________________________________________________________________________________________________________________
STIPULATED PROTECTIVE ORDER
1
EXHIBIT A
2
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
I, _____________________________ [print or type full name], of
4
_________________ [print or type full address], declare under penalty of perjury that I
5
have read in its entirety and understand the Stipulated Protective Order that was issued by
6
the United States District Court for the Central District of California on [date] in the case
7
of ___________ [insert formal name of the case and the number and initials assigned
8
to it by the court]. I agree to comply with and to be bound by all the terms of this
9
Stipulated Protective Order and I understand and acknowledge that failure to so comply
10
could expose me to sanctions and punishment in the nature of contempt. I solemnly
11
promise that I will not disclose in any manner any information or item that is subject to
12
this Stipulated Protective Order to any person or entity except in strict compliance with
13
the provisions of this Order.
14
I further agree to submit to the jurisdiction of the United States District Court for the
15
Northern District of California for the purpose of enforcing the terms of this Stipulated
16
Protective Order, even if such enforcement proceedings occur after termination of this
17
action.
18
I hereby appoint __________________________ [print or type full name] of
19
_______________________________________ [print or type full address and telephone
20
number] as my California agent for service of process in connection with this action or
21
any proceedings related to enforcement of this Stipulated Protective Order.
22
Date: ______________________________________
23
City and State where sworn and signed: _________________________________
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Printed name: _______________________________
26
Signature: __________________________________
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STIPULATED PROTECTIVE ORDER
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