Felanice L Yancy v. United of Omaha Life Insurance Company et al
Filing
23
PROTECTIVE ORDER by Magistrate Judge Patrick J. Walsh re Stipulation for Protective Order 21 (im)
1 Martin E. Rosen (SBN 108998)
mrosen@mail.hinshawlaw.com
2 HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
3 Los Angeles, CA 90071-2043
Telephone: 213-680-2800
4 Facsimile: 213-614-7399
5 Jenny H. Wang (SBN 191643)
jwang@mail.hinshawlaw.com
6 HINSHAW & CULBERTSON LLP
19800 MacArthur Boulevard, Suite 800
7 Irvine, CA 92612
Telephone: 949-757-2800
8 Facsimile: 949-752-6313
9 Attorneys for Defendant United of Omaha
Life Insurance Company
10
11 Corinne Chandler (SBN 111423)
cchandler@kantorlaw.net
12 Glenn R. Kantor (SBN 122643)
gkantor@kantorlaw.net
13 KANTOR & KANTOR LLP
19839 Nordhoff Street
14 Northridge, CA 91324
Telephone: 818-710-2724
15 Facsimile: 818-710-2728
16 Attorneys for Plaintiff Felanice L. Yancy
17
UNITED STATES DISTRICT COURT
18
CENTRAL DISTRICT OF CALIFORNIA
19 Felanice L. Yancy,
20
21
Plaintiff,
vs.
22 United Of Omaha Life Insurance Company,
23
Case No. 2:14-CV-09803PSG(PJWx)
Defendant.
STIPULATED
CONFIDENTIALITY
AGREEMENT AND
PROTECTIVE ORDER
24
Complaint Filed: 12/23/14
25
26
27
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HINSHAW & CULBERTSON
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800
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1.
INTRODUCTION
2
1.1
3
Disclosure and discovery activity in this action are likely to involve
4
production of confidential, proprietary, or private information for which special
5
protection from public disclosure and from use for any purpose other than
6
prosecuting this litigation would be warranted. Accordingly, the parties hereby
7
jointly move the Court to enter the following Protective Order.
8
acknowledge that this Order does not confer blanket protections on all disclosures or
9
responses to discovery and that the protection it affords extends only to the limited
10
information or items that are entitled under the applicable legal principles to
11
treatment as confidential. The parties further acknowledge, as set forth in Section
12
10, below, that this Stipulated Protective Order creates no entitlement to file
13
confidential information under seal; and Local Rule 79- 5.1 sets forth the procedures
14
that must be followed when a party seeks permission from the court to file material
15
under seal.
Purposes and Limitations.
The parties
16
Nothing in this stipulation or Protective Order shall be construed as an
17
admission by either party that discovery outside of the Administrative Record in this
18
ERISA-governed action is appropriate or that any information/documents obtained
19
through any such discovery, including but not limited to reports and testimony of
20
experts, is admissible at trial. The parties hereby specifically reserve their right to
21
object to the taking of discovery outside of the Administrative Record and/or move
22
for a protective order to prevent the same. The parties also reserve their right to
23
object to the admissibility at trial of any information, documents or testimony that is
24
not within the Administrative Record.
25
1.2
26
This action is likely to involve confidential and/or private information of third
27
parties, trade secrets and other valuable research, development, commercial,
28
financial, technical and/or proprietary information for which special protection from
1
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633 West 5th Street, 47th Floor
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213-680-2800
Good Cause Statement.
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public disclosure and from use for any purpose other than prosecution of this action
2
is warranted. Such confidential and proprietary materials and information consist
3
of, among other things, confidential business or financial information, information
4
regarding confidential business practices, or other confidential research,
5
development, or commercial information (including information implicating privacy
6
rights of third parties), information otherwise generally unavailable to the public, or
7
which may be privileged or otherwise protected from disclosure under state or
8
federal statutes, court rules, case decisions, or common law.
9
expedite the flow of information, to facilitate the prompt resolution of disputes over
10
confidentiality of discovery materials, to adequately protect information the parties
11
are entitled to keep confidential, to ensure that the parties are permitted reasonable
12
necessary uses of such material in preparation for and in the conduct of trial, to
13
address their handling at the end of the litigation, and serve the ends of justice, a
14
protective order for such information is justified in this matter. It is the intent of the
15
parties that information will not be designated as confidential for tactical reasons
16
and that nothing be so designated without a good faith belief that it has been
17
maintained in a confidential, non-public manner, and there is good cause why it
18
should not be part of the public record of this case.
19
2.
20
Accordingly, to
DEFINITIONS
2.1
Party: any party to this action, including all of its officers, directors,
21
employees, consultants, retained experts, and outside counsel (and their support
22
staff).
23
2.2
Disclosure or Discovery Material: all items or information, regardless
24
of the medium or manner generated, stored, or maintained (including, among other
25
things, testimony, transcripts, or tangible things) that are produced or generated in
26
disclosures or responses to discovery in this matter.
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HINSHAW & CULBERTSON
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800
2.3
“Confidential” Information or Items: information (regardless of how
generated, stored or maintained) or tangible things that qualify for protection under
2
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standards developed under Rule 26 of the Federal Rules of Civil Procedure
2
(“FRCP”).
3
4
2.4
2.5
2.6
2.7
Protected Material:
any Disclosure or Discovery Material that is
designated as “Confidential.”
11
12
Designating Party: a Party or non-party that designates information or
items that it produces in disclosures or in responses to discovery as “Confidential.”
9
10
Producing Party: a Party or non-party that produces Disclosure or
Discovery Material in this action.
7
8
a Party that receives Disclosure or Discovery
Material from a Producing Party.
5
6
Receiving Party:
2.8
Outside Counsel: attorneys who are not employees of a Party but who
are retained to represent or advise a Party in this action.
13
2.9
14
2.10 Counsel (without qualifier): Outside Counsel and House Counsel (as
15
House Counsel: attorneys who are employees of a Party.
well as their support staffs).
16
2.11 Expert: a person with specialized knowledge or experience in a matter
17
pertinent to the litigation who has been retained by a Party or its counsel to serve as
18
an expert witness or as a consultant in this action and who is not a past or a current
19
employee or of a competitor of a Party’s and who, at the time of retention, is not
20
anticipated to become an employee of a Party or a competitor of a Party’s.
21
2.12 Professional Vendors:
persons or entities that provide litigation
22
support services (e.g., photocopying; videotaping; translating; preparing exhibits or
23
demonstrations; organizing, storing, retrieving data in any form or medium; etc.)
24
and their employees and subcontractors.
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3.
SCOPE
26
The protections conferred by this Stipulation and Order cover not only
27
Protected Material (as defined above), but also any information copied or extracted
28
therefrom, as well as all copies, excerpts, summaries, or compilations thereof, plus
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testimony, conversations, or presentations by parties or counsel to or in court or in
2
other settings that might reveal Protected Material.
3
4.
DURATION
4
Even after the termination of this litigation, the confidentiality obligations
5
imposed by this Order shall remain in effect until a Designating Party agrees
6
otherwise in writing or a court order otherwise directs.
7
5.
8
DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection.
9
Each Party or non-party that designates information or items for protection under
10
this Order must take care to limit any such designation to specific material that
11
qualifies under the appropriate standards. A Designating Party must take care to
12
designate for protection only those parts of material, documents, items, or oral or
13
written communications that qualify — so that other portions of the material,
14
documents, items, or communications for which protection is not warranted are not
15
swept unjustifiably within the ambit of this Order.
16
Mass, indiscriminate, or routinized designations are prohibited. Designations
17
that are shown to be clearly unjustified, or that have been made for an improper
18
purpose (e.g., to unnecessarily encumber or retard the case development process, or
19
to impose unnecessary expenses and burdens on other parties), expose the
20
Designating Party to sanctions.
21
If it comes to a Party’s or a non-party’s attention that information or items
22
that it designated for protection do not qualify for protection at all, or do not qualify
23
for the level of protection initially asserted, that Party or non-party must promptly
24
notify all other parties that it is withdrawing the mistaken designation.
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5.2
Manner and Timing of Designations. Except as otherwise provided in
26
this Order (see, e.g., second paragraph of section 5.2(a), below), or as otherwise
27
stipulated or ordered, material that qualifies for protection under this Order must be
28
clearly so designated before the material is disclosed or produced.
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Designation in conformity with this Order requires:
2
(a)
for information in documentary form (apart from transcripts of
3
depositions or other pretrial or trial proceedings), that the Producing Party affix the
4
Legend “CONFIDENTIAL” at the top or bottom of each page that contains
5
protected material. If only a portion or portions of the material on a page qualifies
6
for protection, the Producing Party also must clearly identify the protected portion(s)
7
(e.g., by making appropriate markings in the margins).
8
A Party or non-party that makes original documents or materials
9
available for inspection need not designate them for protection until after the
10
inspecting Party has indicated which material it would like copied and produced.
11
After the inspecting Party has identified the documents it wants copied and
12
produced, the Producing Party must determine which documents, or portions
13
thereof, qualify for protection under this Order, then, before producing the specified
14
documents,
15
(“CONFIDENTIAL”) at the top or bottom of each page that contains protected
16
Material. If only a portion or portions of the material on a page qualifies for
17
protection, the Producing Party also must clearly identify the protected portion(s)
18
(e.g., by making appropriate markings in the margins).
19
the
(b)
Producing
Party
must
affix
the
appropriate
legend
for testimony given in deposition or in other pretrial or trial
20
proceedings, that the Party or non-party offering or sponsoring the testimony
21
identify on the record, before the close of the deposition, hearing, or other
22
proceeding, all protected testimony. When it is impractical to identify separately
23
each portion of testimony that is entitled to protection, and when it appears that
24
substantial portions of the testimony may qualify for protection, the Party or non-
25
party that sponsors, offers, or gives the testimony may invoke on the record (before
26
the deposition or proceeding is concluded) a right to have up to 20 days after receipt
27
of transcripts from the court reporter to identify the specific portions of the
28
testimony as to which protection is sought. Only those portions of the testimony that
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are appropriately designated for protection within the 20 days shall be covered by
2
the provisions of this Stipulated Protective Order.
3
Transcript pages containing Protected Material must be separately
4
bound by the court reporter, who must affix to the top of each such page the legend
5
“CONFIDENTIAL” as instructed by the Party or nonparty offering or sponsoring
6
the witness or presenting the testimony.
7
(c)
for information produced in some form other than documentary,
8
and for any other tangible items, that the Producing Party affix in a prominent place
9
on the exterior of the container or containers in which the information or item is
10
stored the legend “CONFIDENTIAL.” If only portions of the information or item
11
warrant protection, the Producing Party, to the extent practicable, shall identify the
12
protected portions as “Confidential.”
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5.3
Inadvertent Failures to Designate. If timely corrected, an inadvertent
14
failure to designate qualified information or items as “Confidential” does not,
15
standing alone, waive the Designating Party’s right to secure protection under this
16
Order for such material. If material is appropriately designated as “Confidential”
17
after the material was initially produced, the Receiving Party, on timely notification
18
of the designation, must make reasonable efforts to assure that the material is treated
19
in accordance with the provisions of this Order.
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6.
21
CHALLENGING CONFIDENTIALITY DESIGNATIONS.
6.1
Timing of Challenges. Unless a prompt challenge to a Designating
22
Party’s confidentiality designation is necessary to avoid foreseeable substantial
23
unfairness, unnecessary economic burdens, or a later significant disruption or delay
24
of the litigation, a Party does not waive its right to challenge a confidentiality
25
designation by electing not to mount a challenge promptly after the original
26
designation is disclosed.
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HINSHAW & CULBERTSON
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800
6.2
Meet and Confer.
A Party that elects to initiate a challenge to a
Designating Party’s confidentiality designation must do so in good faith and must
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begin the process by conferring directly (in voice to voice dialogue; other forms of
2
communication are not sufficient) with counsel for the Designating Party.
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conferring, the challenging Party must explain the basis for its belief that the
4
confidentiality designation was not proper and must give the Designating Party an
5
opportunity to review the designated material, to reconsider the circumstances, and,
6
if no change in designation is offered, to explain the basis for the chosen
7
designation. A challenging Party may proceed to the next stage of the challenge
8
process only if it has engaged in this meet and confer process first.
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6.3
In
Judicial Intervention. A Party that elects to press a challenge to a
10
confidentiality designation after considering the justification offered by the
11
Designating Party may file and serve a motion that identifies the challenged material
12
and sets forth in detail the basis for the challenge. Each such motion must be
13
accompanied by a competent declaration that affirms that the movant has complied
14
with the meet and confer requirements imposed in the preceding paragraph and that
15
sets forth with specificity the justification for the confidentiality designation that
16
was given by the Designating Party in the meet and confer dialogue.
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The burden of persuasion in any such challenge proceeding shall be on the
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Designating Party. Until the court rules on the challenge, all parties shall continue to
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afford the material in question the level of protection to which it is entitled under the
20
Producing Party’s designation.
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7.
22
ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is
23
disclosed or produced by another Party or by a non-party in connection with this
24
case only for prosecuting, defending, or attempting to settle this litigation. Such
25
Protected Material may be disclosed only to the categories of persons and under the
26
conditions described in this Order. When the litigation has been terminated, a
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Receiving Party must comply with the provisions of section 11, below (FINAL
28
DISPOSITION).
HINSHAW & CULBERTSON
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
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Protected Material must be stored and maintained by a Receiving Party at a
2
location and in a secure manner that ensures that access is limited to the persons
3
authorized under this Order.
4
7.2
Disclosure of “CONFIDENTIAL” Information or Items.
Unless
5
otherwise ordered by the court or permitted in writing by the Designating Party, a
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Receiving Party may disclose any information or item designated CONFIDENTIAL
7
only to:
8
9
10
(a)
the Receiving Party’s Outside Counsel of record in this action, as
well as employees of said Counsel to whom it is reasonably necessary to disclose
the information for this litigation;
11
(b)
the officers, directors, and employees (including House Counsel)
12
of the Receiving Party to whom disclosure is reasonably necessary for this litigation
13
and;
14
(c)
experts (as defined in this Order) of the Receiving Party to whom
15
disclosure is reasonably necessary for this litigation and who have signed the
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“Agreement to Be Bound by Protective Order” (Exhibit A);
17
(d)
the Court and its personnel;
18
(e)
court reporters, their staffs, and professional vendors to whom
19
20
disclosure is reasonably necessary for this litigation;
(f)
during their depositions, witnesses in the action to whom
21
disclosure is reasonably necessary and who have signed the “Agreement to Be
22
Bound by Protective Order” (Exhibit A). Pages of transcribed deposition testimony
23
or exhibits to depositions that reveal Protected Material must be separately bound by
24
the court reporter and may not be disclosed to anyone except as permitted under this
25
Stipulated Protective Order.
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(g) the author of the document or the original source of the information.
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Los Angeles, CA 90071-2043
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8.
PROTECTED
MATERIAL
SUBPOENAED
OR
ORDERED
2
PRODUCED IN OTHER LITIGATION
3
If a Receiving Party is served with a subpoena or an order issued in other
4
litigation that would compel disclosure of any information or items designated in
5
this action as “CONFIDENTIAL,” the Receiving Party must so notify the
6
Designating Party, in writing (by fax or electronic mail, if possible) immediately and
7
in no event more than three court days after receiving the subpoena or order. Such
8
notification must include a copy of the subpoena or court order. The Receiving
9
Party also must immediately inform in writing the Party who caused the subpoena or
10
order to issue in the other litigation that some or all the material covered by the
11
subpoena or order is the subject of this Protective Order. In addition, the Receiving
12
Party must deliver a copy of this Protective Order promptly to the Party in the other
13
action that caused the subpoena or order to issue.
14
The purpose of imposing these duties is to alert the interested parties to the
15
existence of this Protective Order and to afford the Designating Party in this case an
16
opportunity to try to protect its confidentiality interests in the court from which the
17
subpoena or order issued. The Designating Party shall bear the burdens and the
18
expenses of seeking protection in that court of its confidential material — and
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nothing in these provisions should be construed as authorizing or encouraging a
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Receiving Party in this action to disobey a lawful directive from another court.
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9.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
22
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
23
Protected Material to any person or in any circumstance not authorized under this
24
Protective Order, the Receiving Party must immediately (a) notify in writing the
25
Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
26
all copies of the Protected Material, (c) inform the person or persons to whom
27
unauthorized disclosures were made of all the terms of this Order; and (d) request
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such person or persons to execute the “Acknowledgment and Agreement to Be
2
Bound” that is attached hereto as Exhibit A.
3
10.
FILING PROTECTED MATERIAL
4
Documents designated “CONFIDENTIAL” and all information contained
5
therein or derived therefrom, may be discussed or referred to in pleadings, motions,
6
affidavits, briefs and other papers filed with the Court, or attached as exhibits
7
thereto, provided that such “confidential” documents and information, and any
8
portion of any paper filed with the Court that discusses or refers to them, are
9
stamped “confidential” and separately filed provisionally under seal with the Clerk
10
of the Court. Applicable law, including Civil Local Rule 79-5.1, govern the filing of
11
documents under seal with the District Court.
12
11.
FINAL DISPOSITION
13
Unless otherwise ordered or agreed in writing by the Producing Party, within
14
sixty days after the final termination of this action, each Receiving Party must return
15
all Protected Material to the Producing Party. As used in this subdivision, “all
16
Protected Material” includes all copies, abstracts, compilations, summaries or any
17
other form of reproducing or capturing any of the Protected Material. Alternatively,
18
the Receiving Party may destroy some or all of the Protected Material instead of
19
returning it. Whether the Protected Material is returned or destroyed, the Receiving
20
Party must submit a written certification to the Producing Party (and, if not the same
21
person or entity, to the Designating Party) by the sixty day deadline that affirms that
22
the Receiving Party has not retained any copies, abstracts, compilations, summaries
23
or other forms of reproducing or capturing any of the Protected Material.
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Notwithstanding this provision, Counsel are entitled to retain an archival copy
25
of all pleadings, motion papers, transcripts, legal memoranda, correspondence or
26
attorney work product, even if such materials contain Protected Material. Any such
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archival copies that contain or constitute Protected Material remain subject to this
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Protective Order as set forth in Section 4 (DURATION), above.
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12.
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.
4
12.2 Right to Assert Other Objections. By stipulating to the entry of this
5
Protective Order no Party waives any right it otherwise would have to object to
6
disclosing or producing any information or item on any ground not addressed in this
7
Stipulated Protective Order. Similarly, no Party waives any right to object on any
8
ground to use in evidence of any of the material covered by this Protective Order.
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IT IS SO STIPULATED.
2
DATED: June 26, 2015
HINSHAW & CULBERTSON LLP
3
By: /s/ Jenny H. Wang
Martin E. Rosen
Jenny H. Wang
Attorneys for Defendant United of
Omaha Life Insurance Company
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7
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KANTOR & KANTOR LLP
DATED: June 26, 2015
9
By: /s/ Corinne Chandler
Corinne Chandler
Glenn R. Kantor
Attorneys for Plaintiff Felanice L.
Yancy
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Filer’s Attestation: Pursuant to Local Rule 5-4.3.4(a)(2)(i) regarding signatures,
Corinne Chandler hereby attests that concurrence in the filing of this document and
its content has been obtained by all signatories listed.
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EXHIBIT “A”
2
ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND
3
BY PROTECTIVE ORDER
4
I, ___________________________________, declare as follows:
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1.
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My address is __________________________________________
_______________________________.
2.
My present employer is __________________________________
_______________________________.
3.
My present occupation or job description is _____________________
_______________________________________________________________.
11
I received a copy of the Confidentiality Agreement and Protective Order for
12
the matter of Felanice L. Yancy v. United of Omaha Life Insurance Company,
13
United States District Court, Central District of California, Case No. 2:14-CV-
14
09803-PSG-RZx (“Protective Order”).
15
4.
16
its provisions.
17
5.
I agree to comply with all the provisions of this Protective Order.
18
6.
Subject to the terms of the Protective Order, I will hold in confidence
I have carefully read this Protective Order and certify that I understand
19
and will not disclose to anyone not qualified under the Protective Order, any
20
information contained in the Protected Material that is disclosed to me in this case.
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7.
Subject to the terms of the Protective Order, I will use such information
that is disclosed to me only for purposes of this case.
8.
Upon request, I will return and deliver all Protected Material that
24
comes into my possession, and all documents or things that I have prepared relating
25
thereto, to my counsel in this action, or to counsel for the Party by whom I am
26
employed or retained or from whom I received the Protective Material.
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HINSHAW & CULBERTSON
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800
9.
I hereby submit to the jurisdiction of this Court for the purpose of
enforcing the Protective Order in this case.
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I declare under penalty of perjury under the laws of the United States of
2
America that the foregoing is true and correct.
3
_______________,
4
________________ [State].
20___,
at
Executed this _____ day of
___________________________[City],
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__________________________________
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PROTECTIVE ORDER
2
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Upon consideration of the attached Stipulated Confidentiality Agreement and
Protective Order between the parties in Felanice L. Yancy v. United Of Omaha Life
Insurance Company, Case No. 2:14-CV-09803-PSG(PJWx), the Court hereby
approves of said Agreement and orders the parties to comply with its terms.
Designated “CONFIDENTIAL” Discovery Materials to be produced by any of the
parties shall be subject to this Stipulated Protective Order.
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IT IS SO ORDERED.
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Dated: July 1, 2015
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HON. PATRICK J. WALSH
Magistrate Judge, District Court
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HINSHAW & CULBERTSON
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800
36065082v1 0967637
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36071065v1 0967637
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