Erin C. Jones v. Pennsylvania Higher Education Assistance Agency et al
Filing
33
ORDER GRANTING STIPULATED PROTECTIVE by Magistrate Judge Alexander F. MacKinnon. re Stipulation for Protective Order 32 (sbou)
1
MUSICK, PEELER & GARRETT LLP
ATTORNEYS AT LAW
650 TOWN CENTER DRIVE, SUITE 1200
COSTA MESA, CALIFORNIA 92626-1925
TELEPHONE (714) 668-2400
FACSIMILE (714) 668-2490
2
3 Donald E. Bradley (State Bar No. 145037)
d.bradley@mpglaw.com
4
5 Attorneys for Defendants PENNSYLVANIA HIGHER
6 EDUCATION ASSISTANCE AGENCY and
TRANS UNION LLC
7
8
UNITED STATES DISTRICT COURT
9
CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
10
11
12 ERIN C. JONES,
Case No. 2:16-cv-00107 RSWL (AFMx)
13
Hon. Ronald S. W. Lew, Courtroom 21
Plaintiff,
14
vs.
15
16 PENNSYLVANIA HIGHER
EDUCATION ASSISTANCE
17 AGENCY; EQUIFAX
18 INFORMATION SERVICES, LLC;
EXPERIAN INFORMATION
19 SOLUTIONS, INC.; TRANS UNION,
20 LLC; and DOES 1 to 10, inclusive,
21
[PROPOSED] ORDER GRANTING
STIPULATED PROTECTIVE
ORDER
Defendants.
22
23
24 1.
A.
25
Discovery in this action is likely to involve production of confidential,
PURPOSES AND LIMITATIONS
26 proprietary or private information for which special protection from public
27 disclosure and from use for any purpose other than prosecuting this litigation may
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1006815.1
[PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER
1 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
2 enter the following Stipulated Protective Order. The parties acknowledge that this
3 Order does not confer blanket protections on all disclosures or responses to
4 discovery and that the protection it affords from public disclosure and use extends
5 only to the limited information or items that are entitled to confidential treatment
6 under the applicable legal principles.
7
B.
GOOD CAUSE STATEMENT
8
This action is likely to involve personal and private consumer identification,
9 medical, and other information, trade secrets, and other valuable research,
10 development, commercial, financial, technical and/or proprietary information for
11 which special protection from public disclosure and from use for any purpose other
12 than prosecution of this action is warranted. Such confidential and proprietary
13 materials and information consist of, among other things, confidential business or
14 financial information, information regarding confidential business practices, or other
15 confidential research, development, or commercial information (including
16 information implicating privacy rights of third parties), information otherwise
17 generally unavailable to the public, or which may be privileged or otherwise
18 protected from disclosure under state or federal statutes, court rules, case decisions,
19 or common law. Accordingly, to expedite the flow of information, to facilitate the
20 prompt resolution of disputes over confidentiality of discovery materials, to
21 adequately protect information the parties are entitled to keep confidential, to ensure
22 that the parties are permitted reasonable necessary uses of such material in
23 preparation for and in the conduct of trial, to address their handling at the end of the
24 litigation, and serve the ends of justice, a protective order for such information is
25 justified in this matter. It is the intent of the parties that information will not be
26 designated as confidential for tactical reasons and that nothing be so designated
27 without a good faith belief that it has been maintained in a confidential, non-public
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MUSICK, PEELER
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ATTORNEYS AT LAW
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[PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER
1 manner, and there is good cause why it should not be part of the public record of this
2 case.
3
C.
ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
SEAL
4
The parties further acknowledge, as set forth in Section 12.3, below, that this
5
6 Stipulated Protective Order does not entitle them to file confidential information
7 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
8 and the standards that will be applied when a party seeks permission from the court
9 to file material under seal.
There is a strong presumption that the public has a right of access to judicial
10
11 proceedings and records in civil cases. In connection with non-dispositive motions,
12 good cause must be shown to support a filing under seal. See Kamakana v. City and
13 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
14 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,
15 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
16 require good cause showing), and a specific showing of good cause or compelling
17 reasons with proper evidentiary support and legal justification, must be made with
18 respect to Protected Material that a party seeks to file under seal. The parties’ mere
19 designation of Disclosure or Discovery Material as CONFIDENTIAL does not –
20 without the submission of competent evidence by declaration, establishing that the
21 material sought to be filed under seal qualifies as confidential, privileged, or
22 otherwise protectable – constitute good cause.
Further, if a party requests sealing related to a dispositive motion or trial, then
23
24 compelling reasons, not only good cause, for the sealing must be shown, and the
25 relief sought shall be narrowly tailored to serve the specific interest to be protected.
26 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For
27 each item or type of information, document, or thing sought to be filed or introduced
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[PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER
1 under seal in connection with a dispositive motion or trial, the party seeking
2 protection must articulate compelling reasons, supported by specific facts and legal
3 justification, for the requested sealing order. Again, competent evidence supporting
4 the application to file documents under seal must be provided by declaration.
5
Any document that is not confidential, privileged, or otherwise protectable in
6 its entirety will not be filed under seal if the confidential portions can be redacted.
7 If documents can be redacted, then a redacted version for public viewing, omitting
8 only the confidential, privileged, or otherwise protectable portions of the document,
9 shall be filed. Any application that seeks to file documents under seal in their
10 entirety should include an explanation of why redaction is not feasible.
11 2.
DEFINITIONS
12
2.1
Action: this pending federal lawsuit.
13
2.2
Challenging Party: a Party or Non-Party that challenges the designation
14 of information or items under this Order.
2.3
15
“CONFIDENTIAL” Information or Items: information (regardless of
16 how it is generated, stored or maintained) or tangible things that qualify for
17 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
18 the Good Cause Statement.
2.4
19
Counsel: Outside Counsel of Record and House Counsel (as well as
20 their support staff).
2.5
21
Designating Party: a Party or Non-Party that designates information or
22 items that it produces in disclosures or in responses to discovery as
23 “CONFIDENTIAL.”
2.6
24
Disclosure or Discovery Material: all items or information, regardless
25 of the medium or manner in which it is generated, stored, or maintained (including,
26 among other things, testimony, transcripts, and tangible things), that are produced or
27 generated in disclosures or responses to discovery in this matter.
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1
2.7
Expert: a person with specialized knowledge or experience in a matter
2 pertinent to the litigation who has been retained by a Party or its counsel to serve as
3 an expert witness or as a consultant in this Action.
4
2.8
5
House Counsel: attorneys who are employees of a party to this Action.
6 House Counsel does not include Outside Counsel of Record or any other outside
7 counsel.
2.9
8
Non-Party: any natural person, partnership, corporation, association or
9 other legal entity not named as a Party to this action.
2.10 Outside Counsel of Record: attorneys who are not employees of a
10
11 party to this Action but are retained to represent or advise a party to this Action and
12 have appeared in this Action on behalf of that party or are affiliated with a law firm
13 that has appeared on behalf of that party, and includes support staff.
2.11 Party: any party to this Action, including all of its officers, directors,
14
15 employees, consultants, retained experts, and Outside Counsel of Record (and their
16 support staffs).
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
17
18 Discovery Material in this Action.
2.13 Professional Vendors: persons or entities that provide litigation
19
20 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
21 demonstrations, and organizing, storing, or retrieving data in any form or medium)
22 and their employees and subcontractors.
2.14 Protected Material: any Disclosure or Discovery Material that is
23
24 designated as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery
25
26 Material from a Producing Party.
27 3.
SCOPE
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MUSICK, PEELER
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[PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER
1
The protections conferred by this Stipulation and Order cover not only
2 Protected Material (as defined above), but also (1) any information copied or
3 extracted from Protected Material; (2) all copies, excerpts, summaries, or
4 compilations of Protected Material; and (3) any testimony, conversations, or
5 presentations by Parties or their Counsel that might reveal Protected Material.
6
Any use of Protected Material at trial shall be governed by the orders of the
7 trial judge. This Order does not govern the use of Protected Material at trial.
8 4.
DURATION
9
Once a case proceeds to trial, information that was designated as
10 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
11 as an exhibit at trial becomes public and will be presumptively available to all
12 members of the public, including the press, unless compelling reasons supported by
13 specific factual findings to proceed otherwise are made to the trial judge in advance
14 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
15 showing for sealing documents produced in discovery from “compelling reasons”
16 standard when merits-related documents are part of court record). Accordingly, the
17 terms of this protective order do not extend beyond the commencement of the trial.
18 5.
DESIGNATING PROTECTED MATERIAL
19
5.1
Exercise of Restraint and Care in Designating Material for Protection.
20 Each Party or Non-Party that designates information or items for protection under
21 this Order must take care to limit any such designation to specific material that
22 qualifies under the appropriate standards. The Designating Party must designate for
23 protection only those parts of material, documents, items or oral or written
24 communications that qualify so that other portions of the material, documents, items
25 or communications for which protection is not warranted are not swept unjustifiably
26 within the ambit of this Order.
Mass, indiscriminate or routinized designations are prohibited. Designations
27
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1 that are shown to be clearly unjustified or that have been made for an improper
2 purpose (e.g., to unnecessarily encumber the case development process or to impose
3 unnecessary expenses and burdens on other parties) may expose the Designating
4 Party to sanctions.
5
If it comes to a Designating Party’s attention that information or items that it
6 designated for protection do not qualify for protection, that Designating Party must
7 promptly notify all other Parties that it is withdrawing the inapplicable designation.
8
5.2
Manner and Timing of Designations. Except as otherwise provided in
9 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
10 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
11 under this Order must be clearly so designated before the material is disclosed or
12 produced.
Designation in conformity with this Order requires:
13
(a) for information in documentary form (e.g., paper or electronic
14
15 documents, but excluding transcripts of depositions or other pretrial or trial
16 proceedings), that the Producing Party affix at a minimum, the legend
17 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
18 contains protected material. If only a portion of the material on a page qualifies for
19 protection, the Producing Party also must clearly identify the protected portion(s)
20 (e.g., by making appropriate markings in the margins).
A Party or Non-Party that makes original documents available for inspection
21
22 need not designate them for protection until after the inspecting Party has indicated
23 which documents it would like copied and produced. During the inspection and
24 before the designation, all of the material made available for inspection shall be
25 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
26 documents it wants copied and produced, the Producing Party must determine which
27 documents, or portions thereof, qualify for protection under this Order. Then,
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MUSICK, PEELER
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1 before producing the specified documents, the Producing Party must affix the
2 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
3 portion of the material on a page qualifies for protection, the Producing Party also
4 must clearly identify the protected portion(s) (e.g., by making appropriate markings
5 in the margins).
6
(b) for testimony given in depositions that the Designating Party
7 identifies the Disclosure or Discovery Material on the record, before the close of the
8 deposition all protected testimony.
9
(c) for information produced in some form other than documentary and
10 for any other tangible items, that the Producing Party affix in a prominent place on
11 the exterior of the container or containers in which the information is stored the
12 legend “CONFIDENTIAL.” If only a portion or portions of the information
13 warrants protection, the Producing Party, to the extent practicable, shall identify the
14 protected portion(s).
15
5.3
Inadvertent Failures to Designate. If timely corrected, an inadvertent
16 failure to designate qualified information or items does not, standing alone, waive
17 the Designating Party’s right to secure protection under this Order for such material.
18 Upon timely correction of a designation, the Receiving Party must make reasonable
19 efforts to assure that the material is treated in accordance with the provisions of this
20 Order.
21 6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
22
6.1
Timing of Challenges. Any Party or Non-Party may challenge a
23 designation of confidentiality at any time that is consistent with the Court’s
24 Scheduling Order.
6.2
25
Meet and Confer. The Challenging Party shall initiate the dispute
26 resolution process under Local Rule 37-1 et seq.
6.3
27
Joint Stipulation. Any challenge submitted to the Court shall be via a
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[PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER
1 joint stipulation pursuant to Local Rule 37-2.
2
6.4
The burden of persuasion in any such challenge proceeding shall be on
3 the Designating Party. Frivolous challenges, and those made for an improper
4 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
5 parties) may expose the Challenging Party to sanctions. Unless the Designating
6 Party has waived or withdrawn the confidentiality designation, all parties shall
7 continue to afford the material in question the level of protection to which it is
8 entitled under the Producing Party’s designation until the Court rules on the
9 challenge.
10 7.
ACCESS TO AND USE OF PROTECTED MATERIAL
11
7.1
Basic Principles. A Receiving Party may use Protected Material that is
12 disclosed or produced by another Party or by a Non-Party in connection with this
13 Action only for prosecuting, defending or attempting to settle this Action. Such
14 Protected Material may be disclosed only to the categories of persons and under the
15 conditions described in this Order. When the Action has been terminated, a
16 Receiving Party must comply with the provisions of section 13 below (FINAL
17 DISPOSITION).
Protected Material must be stored and maintained by a Receiving Party at a
18
19 location and in a secure manner that ensures that access is limited to the persons
20 authorized under this Order.
7.2
21
Disclosure of “CONFIDENTIAL” Information or Items. Unless
22 otherwise ordered by the court or permitted in writing by the Designating Party, a
23 Receiving Party may disclose any information or item designated
24 “CONFIDENTIAL” only to:
(a) the Receiving Party’s Outside Counsel of Record in this Action, as
25
26 well as employees of said Outside Counsel of Record to whom it is reasonably
27 necessary to disclose the information for this Action;
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(b) the officers, directors, and employees (including House Counsel) of
2 the Receiving Party to whom disclosure is reasonably necessary for this Action;
3
(c) Experts (as defined in this Order) of the Receiving Party to whom
4 disclosure is reasonably necessary for this Action and who have signed the
5 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
6
(d) the court and its personnel;
7
(e) court reporters and their staff;
8
(f) professional jury or trial consultants, mock jurors, and Professional
9 Vendors to whom disclosure is reasonably necessary for this Action and who have
10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
11
(g) the author or recipient of a document containing the information or
12 a custodian or other person who otherwise possessed or knew the information;
13
(h) during their depositions, witnesses, and attorneys for witnesses, in
14 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
15 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2)
16 they will not be permitted to keep any confidential information unless they sign the
17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
18 agreed by the Designating Party or ordered by the court. Pages of transcribed
19 deposition testimony or exhibits to depositions that reveal Protected Material may
20 be separately bound by the court reporter and may not be disclosed to anyone except
21 as permitted under this Stipulated Protective Order; and
22
(i)
any mediator or settlement officer, and their supporting
23 personnel, mutually agreed upon by any of the parties engaged in settlement
24 discussions.
25 8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
26
IN OTHER LITIGATION
27
If a Party is served with a subpoena or a court order issued in other litigation
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1 that compels disclosure of any information or items designated in this Action as
2 “CONFIDENTIAL,” that Party must:
3
(a) promptly notify in writing the Designating Party. Such notification
4 shall include a copy of the subpoena or court order;
5
(b) promptly notify in writing the party who caused the subpoena or
6 order to issue in the other litigation that some or all of the material covered by the
7 subpoena or order is subject to this Protective Order. Such notification shall include
8 a copy of this Stipulated Protective Order; and
9
(c) cooperate with respect to all reasonable procedures sought to be
10 pursued by the Designating Party whose Protected Material may be affected.
11
If the Designating Party timely seeks a protective order, the Party served with
12 the subpoena or court order shall not produce any information designated in this
13 action as “CONFIDENTIAL” before a determination by the court from which the
14 subpoena or order issued, unless the Party has obtained the Designating Party’s
15 permission. The Designating Party shall bear the burden and expense of seeking
16 protection in that court of its confidential material and nothing in these provisions
17 should be construed as authorizing or encouraging a Receiving Party in this Action
18 to disobey a lawful directive from another court.
19 9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
20
PRODUCED IN THIS LITIGATION
(a) The terms of this Order are applicable to information produced by a
21
22 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
23 produced by Non-Parties in connection with this litigation is protected by the
24 remedies and relief provided by this Order. Nothing in these provisions should be
25 construed as prohibiting a Non-Party from seeking additional protections.
(b) In the event that a Party is required, by a valid discovery request, to
26
27 produce a Non-Party’s confidential information in its possession, and the Party is
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1 subject to an agreement with the Non-Party not to produce the Non-Party’s
2 confidential information, then the Party shall:
3
(1) promptly notify in writing the Requesting Party and the Non-
4
Party that some or all of the information requested is subject to a
5
confidentiality agreement with a Non-Party;
6
(2) promptly provide the Non-Party with a copy of the stipulated
7
Protective Order in this Action, the relevant discovery request(s),
8
and a reasonably specific description of the information
9
requested; and
10
(3) make the information requested available for inspection by
11
the Non-Party, if requested.
12
(c) If the Non-Party fails to seek a protective order from this court
13 within 14 days of receiving the notice and accompanying information, the Receiving
14 Party may produce the Non-Party’s confidential information responsive to the
15 discovery request. If the Non-Party timely seeks a protective order, the Receiving
16 Party shall not produce any information in its possession or control that is subject to
17 the confidentiality agreement with the Non-Party before a determination by the
18 court. Absent a court order to the contrary, the Non-Party shall bear the burden and
19 expense of seeking protection in this court of its Protected Material.
20 10.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
21
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
22 Protected Material to any person or in any circumstance not authorized under this
23 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
24 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
25 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
26 persons to whom unauthorized disclosures were made of all the terms of this Order,
27 and (d) request such person or persons to execute the “Acknowledgment and
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1 Agreement to Be Bound” that is attached hereto as Exhibit A.
2 11.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
3
PROTECTED MATERIAL
4
When a Producing Party gives notice to Receiving Parties that certain
5 inadvertently produced material is subject to a claim of privilege or other protection,
6 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
7 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
8 procedure may be established in an e-discovery order that provides for production
9 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
10 (e), insofar as the parties reach an agreement on the effect of disclosure of a
11 communication or information covered by the attorney-client privilege or work
12 product protection, the parties may incorporate their agreement in the stipulated
13 protective order submitted to the court.
14 12.
MISCELLANEOUS
15
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
16 person to seek its modification by the Court in the future.
12.2 Right to Assert Other Objections. By stipulating to the entry of this
17
18 Protective Order, no Party waives any right it otherwise would have to object to
19 disclosing or producing any information or item on any ground not addressed in this
20 Stipulated Protective Order. Similarly, no Party waives any right to object on any
21 ground to use in evidence of any of the material covered by this Protective Order.
12.3 Filing Protected Material. A Party that seeks to file under seal any
22
23 Protected Material must comply with Local Civil Rule 79-5. Protected Material
24 may only be filed under seal pursuant to a court order authorizing the sealing of the
25 specific Protected Material at issue. If a Party’s request to file Protected Material
26 under seal is denied by the court, then the Receiving Party may file the information
27 in the public record unless otherwise instructed by the court.
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1 13.
FINAL DISPOSITION
2
After the final disposition of this Action, as defined in paragraph 4, within 60
3 days of a written request by the Designating Party, each Receiving Party must return
4 all Protected Material to the Producing Party or destroy such material. As used in
5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
6 summaries, and any other format reproducing or capturing any of the Protected
7 Material. Whether the Protected Material is returned or destroyed, the Receiving
8 Party must submit a written certification to the Producing Party (and, if not the same
9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
10 (by category, where appropriate) all the Protected Material that was returned or
11 destroyed and (2) affirms that the Receiving Party has not retained any copies,
12 abstracts, compilations, summaries or any other format reproducing or capturing any
13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
16 reports, attorney work product, and consultant and expert work product, even if such
17 materials contain Protected Material. Any such archival copies that contain or
18 constitute Protected Material remain subject to this Protective Order as set forth in
19 Section 4 (DURATION).
20 14.
VIOLATION
21
Any violation of this Order may be punished by appropriate measures
22 including, without limitation, contempt proceedings and/or monetary sanctions.
23
PURSUANT TO STIPULATION, IT IS SO ORDERED.
24
25
26 DATED: August 19, 2016
_______________________________
Hon. Alexander F. MacKinnon
United States Magistrate Judge
27
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1
EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
I,
3
[print or type full name], of
4 __________________________________________ [print or type full address],
5 declare under penalty of perjury that I have read in its entirety and understand the
6 Stipulated Protective Order that was issued by the United States District Court for
7 the Central District of California on ______________ [date] in the case of Erin C.
8 Jones v. Pennsylvania Higher Education Assistance Agency, Case No. 2:16-cv9 00107 RSWL (AFMx). I agree to comply with and to be bound by all the terms of
10 this Stipulated Protective Order and I understand and acknowledge that failure to so
11 comply could expose me to sanctions and punishment in the nature of contempt. I
12 solemnly promise that I will not disclose in any manner any information or item that
13 is subject to this Stipulated Protective Order to any person or entity except in strict
14 compliance with the provisions of this Order. I further agree to submit to the
15 jurisdiction of the United States District Court for the Central District of California
16 for enforcing the terms of this Stipulated Protective Order, even if such enforcement
17 proceedings occur after termination of this action. I hereby appoint
18 _______________________ print or type full name] of
19 ______________________________________________ [print or type full address
20 and telephone number] as my California agent for service of process in connection
21 with this action or any proceedings related to enforcement of this Stipulated
22 Protective Order.
23 Date:
24 City and State where sworn and signed:
25 Printed name:
26 Signature:
27
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PROOF OF SERVICE
1
2 STATE OF CALIFORNIA, COUNTY OF ORANGE
3
At the time of service, I was over 18 years of age and not a party to this
4 action. I am employed in the County of Orange, State of California. My business
5 address is 650 Town Center Drive, Suite 1200, Costa Mesa, CA 92626-1925.
6
On August 18, 2016, I served true copies of the following document(s)
7 described as [PROPOSED] ORDER GRANTING STIPULATED
PROTECTIVE ORDER on the interested parties in this action as follows:
8
SEE ATTACHED SERVICE LIST
9
10
11
12
13
BY CM/ECF NOTICE OF ELECTRONIC FILING: I electronically filed
the document(s) with the Clerk of the Court by using the CM/ECF system.
Participants in the case who are registered CM/ECF users will be served by
the CM/ECF system. Participants in the case who are not registered CM/ECF
users will be served by mail or by other means permitted by the court rules.
I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct and that I am employed in the office
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of a member of the bar of this Court at whose direction the service was made.
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Executed on August 18, 2016, at Costa Mesa, California.
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/s/ April M. Yusay
April M. Yusay
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MUSICK, PEELER
& GARRETT LLP
ATTORNEYS AT LAW
1006815.1
16
[PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER
SERVICE LIST
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2 Stuart Price
3 PRICE LAW GROUP, APC
15760 Ventura Boulevard, Suite 800
4 Encino, CA 91436
5 Phone: (818) 907-2030
Fax: (818) 205-3730
6 Email: Stuart@PriceLawGroup.com
7 Attorneys for Plaintiff
Katherine A. Neben
JONES DAY
3161 Michelson Drive, Suite 800
Irvine, CA 92612
Phone: (949) 851-3939
Fax: (949) 553-7539
Email: kneben@jonesday.com
Attorneys for Defendant Experian
Information Solutions, Inc.
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Thomas P. Quinn, Jr.
NOKES AND QUINN
410 Broadway, Suite 200
Laguna Beach, CA 92651
Phone: (949) 376-3500
Fax: (949) 376-3070
Email: tquinn@nokesquinn.com
Attorneys for Defendant Equifax
Information Services, LLC
Paul W. Sheldon
STRASBURGER & PRICE, LLP
2801 Network Boulevard, Suite 600
Frisco, TX 75034
Phone: (469) 287-3955
Fax: (469) 227-6574
Email: Paul.Sheldon@strasburger.com
Attorneys for Defendant Trans Union
LLC
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MUSICK, PEELER
& GARRETT LLP
ATTORNEYS AT LAW
1006815.1
17
[PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER
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