Andy Jang v. Asset Campus Housing, Inc. et al

Filing 40

PROTECTIVE ORDER by Magistrate Judge Patrick J. Walsh 36 . SEE ORDER. (im)

I

1
2
3
4
5

6
7

F

KARL P. SCHLECHT (SBN 182294)
JUDY Y. CHIANG (SBN 210648)
ERIK S. VELIE (SBN 252446)
ELI A. GORDON (SBN 252823)
KIMBALL, TIREY & ST. JOHN LLP
240 Main Street, Suite 500
Irvine, California 92614
Phone:[phone]
Fax:
[phone]

FILED

ct1RK U.S. DISTRICT COURT

’iJTRi

DOFIJFQR
rU

]

Attorneys for Defendant,
ASSET CAMPUS HOUSING, INC.

8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

10
11
12

ANDY JANG, on behalf of himself

13
14

Case No.: 2:15 -cv- 1 927-BRO (PJWx)

and all others similarly situated,

STIPULATED AGREEMENT AND
[PIMD] PROTECTIVE

Plaintiff,

ORDER
V.

15
16

17

ASSET CAMPUS HOUSING, INC.,

;c

q.

Defendants

18

d

19
20

21

t 21,-

b- c%4L

e

a

22

k

23

0cU

24

25

S~e et

26

27
28

ire, U

4

7

d

tv 6D 0 t/V

Case No. 2:15 -cv- 1927 BRO (PJWx)
STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

1

Plaintiff Andy Jang ("Plaintiff") and Defendants Asset Campus Housing,

2

Inc. and Property Solutions International, Inc. ("Defendants") (Plaintiff and

3

Defendants are collectively referred to herein as the "Parties"), through their

4

respective attorneys of record, hereby stipulate and agree that all documents,

5

information and material produced in this case shall be reviewed, used, disclosed

6

and/or disseminated solely for the purposes of this litigation in accordance with the

7

terms set forth below.

8
9

WHEREAS, the parties in the above-titled matter may seek to discover
certain broad categories of documents which may encompass certain intellectual

10

property, and/or confidential, proprietary, business, financial and trade secret

11

information from each other, and

12
13

WHEREAS, the Parties’ attorneys have reasonably conferred on the scope
of this Stipulated Agreement, the Parties do hereby agree to the following:

14

1.

Scope.

15

(a)

The protection of this Stipulated Agreement may be invoked and

16

shall be applied on a narrowly-tailored basis to protect only documents, materials,

17

items, or information that contain, reflect, or incorporate information that is

18

lawfully entitled to confidential treatment under existing California or Federal law

19

(hereinafter "Confidential Information"), including but not limited to trade secrets

20

defined by California Civil Code § 3426.1(d), financial information, personal

21

information, customer information, information submitted to a governmental office

22

but subject to a public policy of confidentiality, or other highly sensitive research,

23

development, production, commercial or business information.

24

(b)

Confidential Information produced by any party or nonparty as part

25

of discovery in this litigation may be designated by such party or nonparty as: (a)

26

"Confidential"; or (b) "Highly Confidential - Attorneys’ Eyes Only" only under the

27

terms of this Stipulated Agreement. Blanket-designation of documents or

28

information as "Confidential" or "Highly Confidential - Attorneys’ Eyes Only" en
2

Case No. 2: 15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

1

masse and/or without regard to the specific contents of each document or piece of

2

information, is prohibited. Upon request, a producing party or nonparty shall

3

produce, if possible, a redacted, public version of a document that has been

4

designated as "Confidential" or "Highly Confidential - Attorneys’ Eyes Only."

5

(c)

As a general guideline, information or materials designated as

6

"Confidential" shall be any information or materials that the producing party

7

reasonably believes constitute or include proprietary business or financial

8

information, or personal information or information furnished to it in confidence by

9

any third party, which information is not known or freely accessible to the general

10

public, and is entitled to protection as provided herein consistent with applicable

11

law.

12

(d)

As a further general guideline, information or materials designated as

13

"Highly Confidential - Attorneys’ Eyes Only" shall be any information or

14

materials that a producing party reasonably and in good faith believes constitute

15

trade secrets or other highly sensitive research, development, production,

16

commercial, or business information (including but not limited to proprietary

17

information, contracts, bids, partner or end-user information, corporate planning

18

documents, strategic planning documents, documents that reveal market or

19

customer analyses, competitive strategy, pricing, research and development

20

documents, financial statements, and other financial or budgetary documents) that

21

might reasonably be of value to the party requesting the document and might

22

reasonably pose a commercial disadvantage to the producing party if disclosed to

23

the party requesting the document, and that is entitled to protection as provided

24

herein consistent with applicable law. Absent a specific order by the Court, once

25

designated as "Highly Confidential - Attorneys’ Eyes Only," such designated

26

information shall be used by the Parties solely in connection with this litigation,

27

and not for any business, competitive, or governmental purpose or function, and

28

such information shall not be disclosed to anyone except as provided herein.
3

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

4

1

(e) Any person designating documents, testimony, or other information as

2

"Confidential" or "Highly Confidential - Attorneys’ Eyes Only" asserts that he

3

believes in good faith that such material, including but not limited to any

4

documents, deposition testimony, written responses to discovery, or other

5

information or materials produced or disclosed during discovery or trial in this case,

6

as well as all pleadings, testimony, exhibits or any other materials, including but not

7

limited to copies, summaries or abstracts of such materials, contains or discloses

8

intellectual property, trade secrets, confidential or proprietary technical, financial or

9

business information, or any other commercially sensitive information that should

10

not be disclosed to anyone except the Parties, their counsel in this litigation

11

(including in-house counsel as described below), and their experts.

12

(f)

Documents, testimony, or other information that is lawfully obtained

13

or obtainable from publicly available sources may not be designated as

14

"Confidential" or "Highly Confidential - Attorneys’ Eyes Only".

15

2.

16

(a) Documents.

17

(i)

Designation of Documents and Depositions.

Designation of a document or group of documents produced by

18

any party or third party as "Confidential" or "Highly Confidential - Attorneys’

19

Eyes Only" shall be made by conspicuously stamping "Confidential" or "Highly

20

Confidential - Attorneys’ Eyes Only" on the document(s) or group(s) of

21

documents at or before the time of production.

22

(ii)

Any third party to this action that produces documents or

23

provides testimony in this action, either voluntarily or by compulsory process,

24

may designate any Confidential Information produced by that third party as

25

"Confidential" or "Highly Confidential - Attorneys’ Eyes Only" pursuant to this

26

Stipulated Agreement to the same extent the Parties may so designate.

27

Furthermore, and notwithstanding the requirements of Paragraph 2(a)(i), all

28

documents produced by a third party shall be treated as "Highly Confidential 4

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

1

Attorneys’ Eyes Only" for a period of thirty (30) days following the date of their

2

production.

3

(iii) At anytime during the thirty (30) day period after which a third

4

party has produced documents, any party to the action may designate any of said

5

documents as "Confidential" or "Highly Confidential - Attorneys’ Eyes Only"

6

pursuant to the provisions of the Stipulated Agreement. The party designating any

7

third-party document as "Confidential" or "Highly Confidential - Attorneys’ Eyes

8

Only" shall provide written notice of the designation to all parties to the action and

9

to the party that produced said document.

10
11

(c) Deposition testimony.
(i)

Designation of a deposition or other pretrial testimony, or

12

portions thereof, as "Confidential" or "Highly Confidential - Attorneys’ Eyes

13

Only" shall be made by a statement on the record by counsel for the party or any

14

third party making the claim of confidentiality at the time of such testimony. The

15

portions of depositions so designated as "Confidential" or "Highly Confidential -

16

Attorneys’ Eyes Only" shall be taken only in the presence of persons qualified to

17

receive such information pursuant to the terms of this Stipulated Agreement: the

18

Parties, the Parties’ experts, the court reporter, the deponent, and the deponent’s

19

attorney. Portions of such deposition transcripts shall be clearly marked as

20

"Confidential" or "Highly Confidential

21

each page, as appropriate.

22

(ii)

-

Attorneys’ Eyes Only" on the cover or on

Any party or third party may designate portions of depositions

23

taken as containing Confidential Information even if not initially marked as

24

"Confidential" or "Highly Confidential - Attorneys’ Eyes Only" by informing

25

counsel for each other party in writing within thirty (30) days of the receipt of the

26

deposition transcript (the "Confidentiality Designation Period") that it seeks to

27

designate "Confidential" or "Highly Confidential - Attorneys’ Eyes Only." Until

28

such time as the Confidentiality Designation Period has elapsed, neither party shall
5

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

1

disclose or use such transcripts or the information contained therein, without

2

treating such information as "Highly Confidential - Attorneys’ Eyes Only."

3

Thereafter each such document or transcript shall be treated in accordance with the

4

terms of this Stipulated Agreement. Any person who receives actual notice of any

5

designation of previously produced documents or deposition transcripts as

6

containing Confidential Information shall treat the information as if it had been

7

designated as "Confidential" or "Highly Confidential - Attorneys’ Eyes Only" at

8

the time he first received it and shall mark all copies in his possession accordingly.

9

(c)

10

Written Discovery Responses.
(i)

In the case of information produced or incorporated in the form

11

of answers to interrogatories, requests for admission, or other written discovery

12

responses, the appropriate confidentiality designation shall be placed in front of the

13

specific answer or response being designated, or on the caption page and also on

14

each page if all of the answers or responses to a particular set of discovery requests

15

are so designated.

16

3.

17

(a) Information or material designated as "Confidential," or copies or

Limitation on Disclosure of Confidential Information.

18

extracts therefrom and compilations and summaries thereof, may be disclosed,

19

summarized, described, characterized, or otherwise communicated or made

20

available in whole or in part only to the following persons:

21

(i)

Parties’ outside counsel in this action and regular and

22

temporary employees of such counsel to whom it is necessary the information or

23

material be shown for the purposes of this litigation;

24
25
26
27

(ii)

any person who is listed on the designated document as an

author or recipient;
(iii)

with respect to (a) documents where the author or recipient is

an entity and (b) documents that are executed or authorized by an entity, any

28
6

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

1

employee or representative of that entity who was involved in the drafting,

2

negotiation, review, or execution of the document;

3

(iv) outside experts, advisors, and consultants (including their

4

employees and support staff) retained by counsel of record in this litigation,

5

provided that such experts, advisors, or consultants shall not be employees of a

6

party or otherwise working for or on behalf of a party in connection with that

7

party’s business. Outside experts, advisors, and consultants must be retained solely

8

for the purpose of advising and assisting outside counsel or giving expert

9

testimony in this action;

10

(v)

11

(vi) deposition and court reporters and their support personnel

12

the Court, its secretaries, clerks, and law clerks;

employed in connection with this action;

13

(vii) graphics or design services retained by counsel for a party for

14

purposes of preparing demonstrative or other exhibits for deposition, trial, or other

15

court proceedings in this action;

16
17
18
19
20
21

(viii) non-technical jury or trial consulting services retained by
counsel for a party; and
(ix) any other person only upon order of the Court or upon prior
written consent of the party producing the Confidential Information or material; and
(x) Parties and employees of the Parties whose assistance is
needed by counsel for the purposes of this litigation.

22

(b) Information or material designated as "Highly Confidential -

23

Attorneys’ Eyes Only," or copies or extracts therefrom and compilations and

24

summaries thereof, may be disclosed, summarized, described, characterized, or

25

otherwise communicated or made available in whole or in part only to the

26

following persons:

27

(i)

all of the persons listed in Paragraph 3(a)(i)-(ix); and

28
7

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

1
2

(ii) in-house attorneys and legal staff of a party who have reason to
view designated documents or groups of documents.

3

(c) Before any person described in paragraphs 3(a) (iv), (vii),

4

(viii), (ix) or 3(b) (ii) receives or is shown any document or information that has

5

been designated "Confidential" or "Highly Confidential - Attorneys’ Eyes Only,"

6

such person shall be given a copy of this Stipulated Agreement and agree in

7

writing, in the form of the Acknowledgement and Agreement attached hereto as

8

Exhibit A, to be bound by its terms. The original and each Acknowledgement and

9

Agreement shall be maintained by counsel. Any counsel may require another

10

counsel to provide a copy of the Acknowledgement and Agreement signed by a

11

witness at a deposition before the witness is deposed with regard to any

12

Confidential Information.

13

(d) Nothing in this Stipulated Agreement shall prevent a party or

14

nonparty from using or disclosing its own materials that it has designated

15

"Confidential" or "Highly Confidential - Attorneys’ Eyes Only."

16

4.

Filing Under Seal.

17

Any papers sought to

18

Confidential Information an-dIi

19

- Attorneys’ Eye...Qfly" shall be filed inrl in accordance with the rules of

20

the Court’reserve the Confidenti

21
22

5.

ed with the Court thatetifffin or reveal

1

as "Coni1’ or "Highly Confidential

ion therein.

Challenge to Confidentiality Designation.
Where any party or third party disagrees with the confidentiality

23

designation of a document or other material, that party has the right to challenge

24

such a designation by written objection. Objections to the confidentiality

25

designation of any document or material shall be served on all Parties, and if the

26

document was produced by a third party, shall be served on the party that produced

27

the document. Any party or third party that asserts the confidentiality of a

28

document or other material as "Confidential" or "Highly Confidential - Attorneys’
8

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

I Eyes Only" shall, within seven (7) days of receiving such objection, attempt to
2 resolve the issue by meeting and conferring with the party who objects to the
3 designation. If the Parties, and, in the case of documents produced by a third party,
4 the person who produced the document, cannot informally resolve the objection to
5

the designation within the seven (7) day period following receipt of the objection,

6 then the party challenging the confidentiality of the material may, at any time
7

during the pendency of the litigation, file a motion requesting that the Court

8

change the confidentiality designation of the materials at issue. The party or third

9

party asserting confidentiality of documents or other information designated as

10 "Confidential" or "Highly Confidential - Attorneys’ Eyes Only" shall ultimately
11 bear the burden of demonstrating the need for the designation. Pending resolution
12

of any dispute, all documents and information designated as "Confidential" or

13 "Highly Confidential - Attorneys’ Eyes Only" shall be protected as such under this
14 Stipulated Agreement.
15

16

6. Survival of Stipulated Agreement - Return of Documents.
(a)

This Stipulated Agreement shall continue in effect until otherwise

17 ordered by the Court. Where the validity of the Stipulated Agreement is challenged
18

by either party, proper notice and an opportunity to be heard in accordance with the

19

requirements of the Federal Rules of Civil Procedure must be afforded to the

20

Parties to this action. The final determination or settlement of this action shall not

21

relieve any person who has received Confidential Information or agreed to be

22

bound by the terms of this Stipulated Agreement of his obligations hereunder. The

23

Court shall retain jurisdiction after such final determination or settlement to

24

enforce this Stipulated Agreement. Subject to Paragraph

25

of the litigation, all Confidential Information as defined in Paragraph 1(b) above,

26

whether originals or copies, shall be destroyed or returned to counsel for the

27

producing party, except that documents on which any person has made notations

28

may be destroyed. Within sixty days of the conclusion of this litigation, the
9

5 above, upon completion

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

4
)

1

attorneys for the receiving party shall provide the attorneys for the producing party

2

a certificate representing that such return or destruction was made.

3

(b) Except as provided in paragraphs 4 or 6, documents or things

4

containing the other party’s or any third party’s Confidential Information shall at

5

all times be in the physical possession of those persons qualifying under paragraph

6

3, or kept by counsel of record at the premises regularly maintained by such

7

counsel of record as and for their respective law offices.

8
9

7. Use of Documents at Trial.
This Stipulated Agreement, except as provided in paragraph 4, shall not

10

apply to information designated or marked "Confidential" or "Highly

11

Confidential Attorneys’ Eyes Only" hereunder that is used during trial in this

12

action. The Parties hereby reserve their rights to use, or seek to limit the disclosure

13

of, Confidential Information at trial.

14

8. Use of Own Documents by Producing Party.

15

Nothing in this Stipulated Agreement shall limit the use by any party,

16

person or entity of documents or information produced or authored by him or his

17

employer.

18

9.

19

Nothing in this Stipulated Agreement shall be construed to confer upon any

Disclosure of Confidential Information to Third Parties.

20

third party the right to access any Confidential Information produced by either

21

party in this action except to the extent that said Confidential Information may be

22

disclosed pursuant to paragraph 3 hereof.

23

10. Applications to Court.

24

(a)

This Stipulated Agreement shall not preclude or limit any party’s right

25

to oppose or object to discovery on any ground that would be otherwise available.

26

This Stipulated Agreement shall not preclude or limit any party’s right to seek in

27

camera review or to seek lesser, further and/or additional protection against or

28
10

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

.

1

limitation upon production or dissemination of information produced in response to

2

discovery, including documents and their contents.

3

(b) Any person to or by whom disclosure or inspection is made in

4

violation of this Stipulated Agreement, and who has knowledge of this Stipulated

5

Agreement, shall be bound by its terms.

6

(c) If any person violates or threatens to violate this Stipulated Agreement,

7

the Parties agree that the aggrieved party may immediately apply to obtain

8, injunctive relief against any such person. All persons subject to this Stipulated
9

Agreement agree that the Court shall retain jurisdiction over them for the purposes

10

of enforcing this Stipulated Agreement, including, but not limited to issuing an

11

injunction, imposing sanctions, or holding any person in contempt of court.

12

(d) If any deponent required by this Stipulated Agreement to execute the

13

written Acknowledgment and Agreement described in paragraph 3(c) refuses to do

14

so, the Parties may complete the deposition on other matters or adjourn it and move

15

the Court for any appropriate relief, including (without limitation) an order that the

16

deponent shall execute the written agreement described in paragraph 3(c), or an

17

order that deponent shall be bound by the terms of this Stipulated Agreement. Any

18

nonparty whose Confidential Information is the subject of such a motion shall be

19

given notice thereof. Alternatively, if any individual deponent refuses to execute the

20

Stipulated Agreement, the Parties shall not disclose any Confidential Information to

21

that individual.

22

11. Agreement to Cooperate.

23

The Parties and their respective attorneys of record agree that, when a

24

party’s attorney requests a deponent to sign the written Acknowledgment and

25

Agreement described in paragraph 3(c), the other party’s attorney will join in such

26

request, unless that attorney has a good faith basis for refusing to join in such

27

request; provided, however, that this requirement shall not apply with respect to

28

any deponent who is represented at his deposition by an attorney of record for any
11

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

1

party hereto (including any member or associate of their respective law firms). An

2

attorney’s request to sign an acknowledgment shall not be construed as legal

3

advice to the deponent or a waiver of any position concerning confidentiality, but

4

shall and may be stated to be a request to facilitate discovery.

5

12. No Admissions.

6

Neither entering into this Stipulated Agreement, nor receiving any

7

documents or other information designated as "Confidential"

8

Confidential - Attorneys’ Eyes Only" shall be construed as an agreement or

9

admission (1) that any document or information designated as "Confidential" or

10

"Highly Confidential - Attorneys’ Eyes Only" merits protection as Confidential

11

Information; (2) as to the correctness or truth of any allegation made or position

12

taken relative to any matter designated as "Confidential" or "Highly Confidential -

13

Attorneys’ Eyes Only"; or (3) as to the authenticity, competency, relevance,

14

materiality, or admissibility of any information or document designated as

15

"Confidential" or "Highly Confidential - Attorneys’ Eyes Only."

or "Highly

16

13.

17

The Parties agree that inadvertent production of documents or information

18

subject to any applicable privilege, including but not limited to the attorney-client

19

privilege or work product doctrine, despite reasonable efforts to screen such

20

documents and information prior to production, does not waive such applicable

21

privilege or protection, provided a request for return of such documents or

22

information is made promptly upon learning of such inadvertent production. Once

23

a request for the return of inadvertently produced documents has been made, the

24

receiving party shall, within ten calendar days, return the inadvertently produced

25

materials, and all copies of those materials that may have been made, and any

26

notes regarding those materials shall be destroyed. If a party, through inadvertence,

27

has produced any Confidential Information without labeling or otherwise

28

designating it as such in accordance with terms of this Stipulated Agreement, the

Inadvertent Production.

12

Case No. 2:15-cv-1927 BRO(PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

I

producing party may request that the document or information previously produced

2

without such designation be deemed as "Confidential" or "Highly Confidential -

3 Attorneys’ Eyes Only" by giving written notice. The receiving party shall treat the
4 documents or information accordingly upon being notified as such. Any disclosure
5

prior to receipt of such notice to persons not authorized under this Stipulated

6 Agreement shall not be considered a violation of this Stipulated Agreement,
7

provided that the disclosing party promptly retrieves such later-designated

8 Confidential Information and notifies the other party in writing of all the persons to
9

whom such disclosure was made and the scope and extent of such disclosure. For

10 purposes of this Stipulated Agreement, inadvertent production refers to
11 circumstances where the producing party took reasonable precautions, but an error
12

was made in the production of the information without the knowledge of the

13

producing party’s attorney.

14

14. No Waiver of Privilege or Other Objections.

15

Nothing in this Stipulated Agreement shall require disclosure of material

16 that counsel for a party contends is protected from disclosure by the attorney17

client privilege, the attorney work-product immunity doctrine, or any other legal

18 privilege. Moreover, the Parties hereto specifically reserve the right to object to,
19

or to seek a protective order concerning, the disclosure of any Confidential

20

Information. Nothing in this Stipulated Agreement shall be construed as a waiver

21

of the right of any party to object to the taking or the admissibility of any

22

testimony, documents, or other evidence where such objection is based on grounds

23

other than that the testimony, documents or evidence involves Confidential

24

Information. The Parties hereto specifically reserve the right to raise all

25

appropriate objections, such as relevancy, to any request for testimony, documents

26

or other evidence, or the admissibility thereof.

27
28
13

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

1

15. Disclosure in Violation of Stipulated Agreement.

2

(a) If any Confidential Information is disclosed to any person other than

3 in the manner authorized by this Stipulated Agreement, the party responsible for
4 the disclosure must immediately inform all other Parties of all facts pertinent to the
5

disclosure, and without prejudice to the rights and remedies of the designating

6 party, make every effort to prevent further unauthorized disclosure on its own part
7

8
9

or on the part of the recipient of such Confidential Information.
(b) If any party receives a subpoena or document request from a
government agency or third party in a judicial or administrative proceeding that

10 calls for the production of documents produced by the other party, the receiving
11 party shall promptly inform the producing party in writing of the subpoena or
12 request. A party receiving a subpoena shall not produce responsive documents
13 unless the subpoenaed party has given notice to, and allowed ample opportunity for
14 the other party to seek appropriate relief, as governed by the rules, law, and other
15

legal authority applicable to the subpoena.

16

16.

17

Any party may seek modification of this Stipulated Agreement upon proper

ModificationFurther Agreements.

18 notice or enter into other written agreements designed to protect Confidential
19

Information.

20
21
22
23
24
25
26
27

28
14

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

1

Respectfully submitted,
LAW OFFICES OF RON BOCHNER

2

3 Dated: September 24, 2015

By: /s/ Ron K. Bochner
Ron K. Bochner

4

Attorney for Plaintiff

5

6

KIMBALL TIREY & ST. JOHN LLP

7

8 Dated: September 24, 2015

By:
Is! Erik S. Velie
Erik S. Velie

9

Attorneys for Defendant

10
11
12

PURSUANT TO STIPULATION, IT IS SO ORDERED.

xa’j

13

14
15

Dated:

mt-5
’

~)

HorickJ.Walsh
U.S. District Judge

16

17
18
19
20
21
22
23
24
25
26
27
28
15

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

)

1

EXHIBIT A

2
3

I,

4

I have been given a copy of and have read the Stipulated Agreement and

, declare that:

5

[Proposed] Protective Order ("Stipulated Agreement") entered in the case entitled:

6

Andy Jang v. Asset Campus Housing, Inc., Case No. 2:15 -cv- 1927 BRO (PJWx)

7

(United States District Court, Central District of California). I agree to abide by the

8

Stipulated Agreement and not to reveal or otherwise communicate to anyone or

9

utilize any of the information designated "Confidential" or "Highly Confidential -

10

Attorneys’ Eyes Only" that is disclosed to me except in accordance with the terms

11

of such Stipulated Agreement. I acknowledge that any intentional violation of the

12

Stipulated Agreement may be punishable as contempt of the Court or through

13

monetary sanctions ordered by the Court, or both.

14
15
16

DATED:
Signature

17
18
19
20
21
22
23
24
25
26
27
28
1

Case No. 2:15-cv-1927 BRO (PJWx)

STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER

PROOF OF SERVICE

I
2

I, Holly Foreman, declare:

I am, and was at the time of service of the papers herein referred to, over the
4 age of eighteen (18) years and not a party to the within action. I am employed in
the County of Orange, California, in which county the within-mentioned mailing
occurred. My business address is 2040 Main Street, Suite 500, Irvine, California
92614.
6 On September 25, 2015, I served the following document(s):
STIPULATED AGREEMENT AND [PROPOSED] PROTECTIVE ORDER
8

on the following parties:

9

Ron K. Bochner, Esq.
10 LAW OFFICES OF RON BOCHNER
232 E. Anapama Street
Santa Barbara, CA 93101
12 Email: [e-mail]
13

(BY MAIL) I placed a true and correct copy of the document(s) in a
sealed envelope addressed as follows and I caused the envelope to be
deposited in the mail at Irvine, California. The envelope was mailed
with postage thereon fully prepaid.

14
15

16 XX
17
18
19
20
21
22
23

(BY ELECTRONIC SERVICE) I caused such document(s) to be
electronically served through NEF to the above electronic notification
addresses. The file transmission was reported as complete and a copy
of the "NEF Filing Receipt" page will be maintained with the original
document(s) in our office.
(BY OVERNIGHT MAIL) I placed a true and correct copy of the
document(s) in a sealed envelope addressed as follows and I caused
the envelope to be deposited with GSO at Irvine, California.

I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.
Executed on September 25, 2015, at Irvine, California.

24

Is! Holly Foreman
Holly Foreman

25
26
27
28
1

PROOF OF SERVICE

Case No. 2:15-cv-1927_BRO(PJWx)