Broadway Financial Corporation v. Continental Casualty Company et al

Filing 30

PROTECTIVE ORDER by Magistrate Judge Karen L. Stevenson re Stipulation for Protective Order 29 (See order for details) (rh)

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GARY J. VALERIANO (Bar No. 89644)
[e-mail]
MARK J. KRONE (Bar No. 219806)
[e-mail]
ANDERSON, McPHARLIN & CONNERS LLP
707 Wilshire Boulevard
Suite 4000
Los Angeles, California 90017-3623
TELEPHONE: [phone]  FACSIMILE: [phone]

6 Attorneys for Defendant
COLUMBIA CASUALTY COMPANY
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8

UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

LOS ANGELES, CALIFORNIA 90017-3623

LAWYERS

707 WILSHIRE BOULEVARD, SUITE 4000

ANDERSON, MCPHARLIN & CONNERS LLP 

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11 BROADWAY FINANCIAL
CORPORATION,
12
Plaintiff,
13
vs.
14
CONTINENTAL CASUALTY
15 COMPANY; COLUMBIA
CASUALTY COMPANY; and DOES 1
16 through 10,

Case No. 2:16-cv-2983 RGK-KS
STIPULATED PROTECTIVE
ORDER
Trial Date:

May 9, 2017

Defendants.

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18
19 1.

A.

PURPOSES AND LIMITATIONS

20

Discovery in this action is likely to involve production of confidential,

21 proprietary, or private information for which special protection from public
22 disclosure and from use for any purpose other than prosecuting this litigation may
23 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
24 enter the following Stipulated Protective Order. The parties acknowledge that this
25 Order does not confer blanket protections on all disclosures or responses to
26 discovery and that the protection it affords from public disclosure and use extends
27 only to the limited information or items that are entitled to confidential treatment
28 under the applicable legal principles. The parties further acknowledge, as set forth in
1550129.1 05303-699

STIPULATED PROTECTIVE ORDER

1 Section 12.3, below, that this Stipulated Protective Order does not entitle them to
2 file confidential information under seal; Civil Local Rule 79-5 sets forth the
3 procedures that must be followed and the standards that will be applied when a party
4 seeks permission from the court to file material under seal.
5

B.

GOOD CAUSE STATEMENT

6

This action is likely to involve trade secrets, customer and pricing lists and

7 other valuable research, development, commercial, financial, technical and/or
8 proprietary information for which special protection from public disclosure and
9 from use for any purpose other than prosecution of this action is warranted. Such

LOS ANGELES, CALIFORNIA 90017-3623

LAWYERS

11 things, information implicating privacy rights of third parties including but not
707 WILSHIRE BOULEVARD, SUITE 4000

ANDERSON, MCPHARLIN & CONNERS LLP 

10 confidential and proprietary materials and information consist of, among other

12 limited to loan applications, loan applicants’ financial records, financial account
13 information, banking information, and loan payment and performance information.
14 Additionally, the parties which are in the business of insurance and banking, will
15 likely disclose information regarding their confidential business practices, trade
16 secret or other proprietary information including but not limited to company
17 manuals, procedures, guides and training materials; attorney fee billing invoices;
18 investigative and audit reports; underwriting information; attorney-client or work
19 product information; reinsurance information; and reserve information.
20 Additionally, this action will likely involve confidential communications between
21 the parties and law enforcement personnel and information otherwise generally
22 unavailable to the public, or which may be privileged or otherwise protected from
23 disclosure under state or federal statutes, court rules, case decisions, or common
24 law.
25

Accordingly, to expedite the flow of information, to facilitate the prompt

26 resolution of disputes over confidentiality of discovery materials, to adequately
27 protect information the parties are entitled to keep confidential, to ensure that the
28 parties are permitted reasonable necessary uses of such material in preparation for
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2

STIPULATED PROTECTIVE ORDER

1 and in the conduct of trial, to address their handling at the end of the litigation, and
2 serve the ends of justice, a protective order for such information is justified in this
3 matter. It is the intent of the parties that information will not be designated as
4 confidential for tactical reasons and that nothing be so designated without a good
5 faith belief that it has been maintained in a confidential, non-public manner, and
6 there is good cause why it should not be part of the public record of this case.
7 2.

DEFINITIONS

8

2.1

Action: this pending federal law suit.

9

2.2

Challenging Party: a Party or Non-Party that challenges the designation

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LAWYERS

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10 of information or items under this Order.
2.3

“CONFIDENTIAL” Information or Items: information (regardless of

12 how it is generated, stored or maintained) or tangible things that qualify for
13 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
14 the Good Cause Statement.
15

2.4

Counsel: Outside Counsel of Record and House Counsel (as well as

16 their support staff).
17

2.5

Designating Party: a Party or Non-Party that designates information or

18 items that it produces in disclosures or in responses to discovery as
19 “CONFIDENTIAL.”
20

2.6

Disclosure or Discovery Material: all items or information, regardless

21 of the medium or manner in which it is generated, stored, or maintained (including,
22 among other things, testimony, transcripts, and tangible things), that are produced or
23 generated in disclosures or responses to discovery in this matter.
24

2.7

Expert: a person with specialized knowledge or experience in a matter

25 pertinent to the litigation who has been retained by a Party or its counsel to serve as
26 an expert witness or as a consultant in this Action.
27 / / /
28 / / /
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STIPULATED PROTECTIVE ORDER

1

2.8

House Counsel: attorneys who are employees of a party to this Action.

2 House Counsel does not include Outside Counsel of Record or any other outside
3 counsel.
4

2.9

Non-Party: any natural person, partnership, corporation, association, or

5 other legal entity not named as a Party to this action.
6

2.10 Outside Counsel of Record: attorneys who are not employees of a party

7 to this Action but are retained to represent or advise a party to this Action and have
8 appeared in this Action on behalf of that party or are affiliated with a law firm which
9 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,

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11 employees, consultants, retained experts, and Outside Counsel of Record (and their
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12 support staffs).
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2.12 Producing Party: a Party or Non-Party that produces Disclosure or

14 Discovery Material in this Action.
15

2.13 Professional Vendors: persons or entities that provide litigation support

16 services (e.g., photocopying, videotaping, translating, preparing exhibits or
17 demonstrations, and organizing, storing, or retrieving data in any form or medium)
18 and their employees and subcontractors.
19

2.14 Protected Material: any Disclosure or Discovery Material that is

20 designated as “CONFIDENTIAL.”
21

2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

22 from a Producing Party.
23 3.

SCOPE

24

The protections conferred by this Stipulation and Order cover not only

25 Protected Material (as defined above), but also (1) any information copied or
26 extracted from Protected Material; (2) all copies, excerpts, summaries, or
27 compilations of Protected Material; and (3) any testimony, conversations, or
28 presentations by Parties or their Counsel that might reveal Protected Material.
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STIPULATED PROTECTIVE ORDER

1

Any use of Protected Material at trial shall be governed by the orders of the

2 trial judge. This Order does not govern the use of Protected Material at trial.
3 4.

DURATION

4

Even after final disposition 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. Final disposition shall be
7 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
8 or without prejudice; and (2) final judgment herein after the completion and
9 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

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LAWYERS

11 pursuant to applicable law.
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10 including the time limits for filing any motions or applications for extension of time
12 5.

DESIGNATING PROTECTED MATERIAL

13

5.1

Exercise of Restraint and Care in Designating Material for Protection.

14 Each Party or Non-Party that designates information or items for protection under
15 this Order must take care to limit any such designation to specific material that
16 qualifies under the appropriate standards. The Designating Party must designate for
17 protection only those parts of material, documents, items, or oral or written
18 communications that qualify so that other portions of the material, documents,
19 items, or communications for which protection is not warranted are not swept
20 unjustifiably within the ambit of this Order.
21

Mass, indiscriminate, or routinized designations are prohibited. Designations

22 that are shown to be clearly unjustified or that have been made for an improper
23 purpose (e.g., to unnecessarily encumber the case development process or to impose
24 unnecessary expenses and burdens on other parties) may expose the Designating
25 Party to sanctions.
26

If it comes to a Designating Party’s attention that information or items that it

27 designated for protection do not qualify for protection, that Designating Party must
28 promptly notify all other Parties that it is withdrawing the inapplicable designation.
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STIPULATED PROTECTIVE ORDER

1

5.2

Manner and Timing of Designations. Except as otherwise provided in

2 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
4 under this Order must be clearly so designated before the material is disclosed or
5 produced.
6

Designation in conformity with this Order requires:

7

(a)

for information in documentary form (e.g., paper or electronic

8 documents, but excluding transcripts of depositions or other pretrial or trial
9 proceedings), that the Producing Party affix at a minimum, the legend

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LAWYERS

11 contains protected material. If only a portion or portions of the material on a page
707 WILSHIRE BOULEVARD, SUITE 4000

ANDERSON, MCPHARLIN & CONNERS LLP 

10 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

12 qualifies for protection, the Producing Party also must clearly identify the protected
13 portion(s) (e.g., by making appropriate markings in the margins).
14

A Party or Non-Party that makes original documents available for inspection

15 need not designate them for protection until after the inspecting Party has indicated
16 which documents it would like copied and produced. During the inspection and
17 before the designation, all of the material made available for inspection shall be
18 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
19 documents it wants copied and produced, the Producing Party must determine which
20 documents, or portions thereof, qualify for protection under this Order. Then, before
21 producing the specified documents, the Producing Party must affix the
22 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
23 portion or portions of the material on a page qualifies for protection, the Producing
24 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
25 markings in the margins).
26

(b)

for testimony given in depositions that the Designating Party identify

27 the Disclosure or Discovery Material on the record, before the close of the
28 deposition all protected testimony.
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STIPULATED PROTECTIVE ORDER

1

(c)

for information produced in some form other than documentary and for

2 any other tangible items, that the Producing Party affix in a prominent place on the
3 exterior of the container or containers in which the information is stored the legend
4 “CONFIDENTIAL.” If only a portion or portions of the information warrants
5 protection, the Producing Party, to the extent practicable, shall identify the protected
6 portion(s).
7

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

8 failure to designate qualified information or items does not, standing alone, waive
9 the Designating Party’s right to secure protection under this Order for such material.

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LAWYERS

11 efforts to assure that the material is treated in accordance with the provisions of this
707 WILSHIRE BOULEVARD, SUITE 4000

ANDERSON, MCPHARLIN & CONNERS LLP 

10 Upon timely correction of a designation, the Receiving Party must make reasonable

12 Order.
13 6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

14

6.1

Timing of Challenges. Any Party or Non-Party may challenge a

15 designation of confidentiality at any time that is consistent with the Court’s
16 Scheduling Order.
17

6.2

Meet and Confer. The Challenging Party shall initiate the dispute

18 resolution process under Local Rule 37.1 et seq.
19

6.3

The burden of persuasion in any such challenge proceeding shall be on

20 the Designating Party. Frivolous challenges, and those made for an improper
21 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
22 parties) may expose the Challenging Party to sanctions. Unless the Designating
23 Party has waived or withdrawn the confidentiality designation, all parties shall
24 continue to afford the material in question the level of protection to which it is
25 entitled under the Producing Party’s designation until the Court rules on the
26 challenge.
27 / / /
28 / / /
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STIPULATED PROTECTIVE ORDER

1 7.

ACCESS TO AND USE OF PROTECTED MATERIAL

2

7.1

Basic Principles. A Receiving Party may use Protected Material that is

3 disclosed or produced by another Party or by a Non-Party in connection with this
4 Action only for prosecuting, defending, or attempting to settle this Action. Such
5 Protected Material may be disclosed only to the categories of persons and under the
6 conditions described in this Order. When the Action has been terminated, a
7 Receiving Party must comply with the provisions of section 13 below (FINAL
8 DISPOSITION).
9

Protected Material must be stored and maintained by a Receiving Party at a

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LAWYERS

11 authorized under this Order.
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10 location and in a secure manner that ensures that access is limited to the persons

12

7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

13 otherwise ordered by the court or permitted in writing by the Designating Party, a
14 Receiving Party may disclose any information or item designated
15 “CONFIDENTIAL” only to:
16

(a)

the Receiving Party’s Outside Counsel of Record in this Action, as well

17 as employees of said Outside Counsel of Record to whom it is reasonably necessary
18 to disclose the information for this Action;
19

(b)

the officers, directors, and employees (including House Counsel) of the

20 Receiving Party to whom disclosure is reasonably necessary for this Action;
21

(c)

Experts (as defined in this Order) of the Receiving Party to whom

22 disclosure is reasonably necessary for this Action and who have signed the
23 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
24

(d)

the court and its personnel;

25

(e)

court reporters and their staff;

26

(f)

professional jury or trial consultants, mock jurors, and Professional

27 Vendors to whom disclosure is reasonably necessary for this Action and who have
28 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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STIPULATED PROTECTIVE ORDER

1

(g)

the author or recipient of a document containing the information or a

2 custodian or other person who otherwise possessed or knew the information;
3

(h)

during their depositions, witnesses, and attorneys for witnesses, in the

4 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
5 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
6 not be permitted to keep any confidential information unless they sign the
7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
8 agreed by the Designating Party or ordered by the court. Pages of transcribed
9 deposition testimony or exhibits to depositions that reveal Protected Material may

LOS ANGELES, CALIFORNIA 90017-3623

LAWYERS

11 as permitted under this Stipulated Protective Order; and
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10 be separately bound by the court reporter and may not be disclosed to anyone except

12

(i)

any mediator or settlement officer, and their supporting personnel,

13 mutually agreed upon by any of the parties engaged in settlement discussions.
14 8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED

15 PRODUCED IN OTHER LITIGATION
16

If a Party is served with a subpoena or a court order issued in other litigation

17 that compels disclosure of any information or items designated in this Action as
18 “CONFIDENTIAL,” that Party must:
19

(a)

promptly notify in writing the Designating Party. Such notification

20 shall include a copy of the subpoena or court order;
21

(b)

promptly notify in writing the party who caused the subpoena or order

22 to issue in the other litigation that some or all of the material covered by the
23 subpoena or order is subject to this Protective Order. Such notification shall include
24 a copy of this Stipulated Protective Order; and
25

(c)

cooperate with respect to all reasonable procedures sought to be

26 pursued by the Designating Party whose Protected Material may be affected.
27

If the Designating Party timely seeks a protective order, the Party served with

28 the subpoena or court order shall not produce any information designated in this
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9

STIPULATED PROTECTIVE ORDER

1 action as “CONFIDENTIAL” before a determination by the court from which the
2 subpoena or order issued, unless the Party has obtained the Designating Party’s
3 permission. The Designating Party shall bear the burden and expense of seeking
4 protection in that court of its confidential material and nothing in these provisions
5 should be construed as authorizing or encouraging a Receiving Party in this Action
6 to disobey a lawful directive from another court.
7 9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

8 PRODUCED IN THIS LITIGATION
9

(a)

The terms of this Order are applicable to information produced by a

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LAWYERS

11 produced by Non-Parties in connection with this litigation is protected by the
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10 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

12 remedies and relief provided by this Order. Nothing in these provisions should be
13 construed as prohibiting a Non-Party from seeking additional protections.
14

(b)

In the event that a Party is required, by a valid discovery request, to

15 produce a Non-Party’s confidential information in its possession, and the Party is
16 subject to an agreement with the Non-Party not to produce the Non-Party’s
17 confidential information, then the Party shall:
(1)

18

promptly notify in writing the Requesting Party and the Non-

19 Party that some or all of the information requested is subject to a confidentiality
20 agreement with a Non-Party;
(2)

21

promptly provide the Non-Party with a copy of the Stipulated

22 Protective Order in this Action, the relevant discovery request(s), and a reasonably
23 specific description of the information requested; and
(3)

24

make the information requested available for inspection by the

25 Non-Party, if requested.
26

(c)

If the Non-Party fails to seek a protective order from this court within

27 14 days of receiving the notice and accompanying information, the Receiving Party
28 may produce the Non-Party’s confidential information responsive to the discovery
1550129.1 05303-699

10

STIPULATED PROTECTIVE ORDER

1 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
2 not produce any information in its possession or control that is subject to the
3 confidentiality agreement with the Non-Party before a determination by the court.
4 Absent a court order to the contrary, the Non-Party shall bear the burden and
5 expense of seeking protection in this court of its Protected Material.
6 10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

7

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

8 Protected Material to any person or in any circumstance not authorized under this
9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in

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LAWYERS

11 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
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10 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

12 persons to whom unauthorized disclosures were made of all the terms of this Order,
13 and (d) request such person or persons to execute the “Acknowledgment and
14 Agreement to Be Bound” that is attached hereto as Exhibit A.
15 11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

16 PROTECTED MATERIAL
17

When a Producing Party gives notice to Receiving Parties that certain

18 inadvertently produced material is subject to a claim of privilege or other protection,
19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
21 may be established in an e-discovery order that provides for production without
22 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
23 as the parties reach an agreement on the effect of disclosure of a communication or
24 information covered by the attorney-client privilege or work product protection, the
25 parties may incorporate their agreement in the stipulated protective order submitted
26 to the court.
27 12.

MISCELLANEOUS

28

12.1 Right to Further Relief. Nothing in this Order abridges the right of any

1550129.1 05303-699

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STIPULATED PROTECTIVE ORDER

1 person to seek its modification by the Court in the future.
2

12.2 Right to Assert Other Objections. By stipulating to the entry of this

3 Protective Order no Party waives any right it otherwise would have to object to
4 disclosing or producing any information or item on any ground not addressed in this
5 Stipulated Protective Order. Similarly, no Party waives any right to object on any
6 ground to use in evidence of any of the material covered by this Protective Order.
7

12.3 Filing Protected Material. A Party that seeks to file under seal any

8 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
9 only be filed under seal pursuant to a court order authorizing the sealing of the

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LAWYERS

11 under seal is denied by the court, then the Receiving Party may file the information
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10 specific Protected Material at issue. If a Party's request to file Protected Material

12 in the public record unless otherwise instructed by the court.
13 13.

FINAL DISPOSITION

14

After the final disposition of this Action, as defined in paragraph 4, within 60

15 days of a written request by the Designating Party, each Receiving Party must return
16 all Protected Material to the Producing Party or destroy such material. As used in
17 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
18 summaries, and any other format reproducing or capturing any of the Protected
19 Material. 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 60 day deadline that (1) identifies
22 (by category, where appropriate) all the Protected Material that was returned or
23 destroyed and (2)affirms that the Receiving Party has not retained any copies,
24 abstracts, compilations, summaries or any other format reproducing or capturing any
25 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
26 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
27 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
28 reports, attorney work product, and consultant and expert work product, even if such

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STIPULATED PROTECTIVE ORDER

1 materials contain Protected Material. Any such archival copies that contain or
2 constitute Protected Material remain subject to this Protective Order as set forth in
3 Section 4 (DURATION).
4

14.

Any violation of this Order may be punished by any and all appropriate

5 measures including, without limitation, contempt proceedings and/or monetary
6 sanctions.
7
8 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
9 DATED: January 4, 2017

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LAWYERS

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10

Karen L. Stevenson
United States Magistrate Judge

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STIPULATED PROTECTIVE ORDER

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

I,____________________________________[print or type full name], of

4 ____________________________ [print or type full address], declare under penalty
5 of perjury that I have read in its entirety and understand the Stipulated Protective
6 Order that was issued by the United States District Court for the Central District of
7 California on [date] in the case of Broadway Financial Corporation v. Continental
8 Casualty Company et al., United States District Court for the Central District Of
9 California, Case No. 2:16-cv-02983-RGK-KS. I agree to comply with and to be

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11 acknowledge that failure to so comply could expose me to sanctions and punishment
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10 bound by all the terms of this Stipulated Protective Order and I understand and

12 in the nature of contempt. I solemnly promise that I will not disclose in any manner
13 any information or item that is subject to this Stipulated Protective Order to any
14 person or entity except in strict compliance with the provisions of this Order.
15

I further agree to submit to the jurisdiction of the United States District Court

16 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint ____________________________ [print
19 or type full name] of _______________________________________ [print or type
20 full address and telephone number] as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 Date:
24 City and State where sworn and signed:
25 Printed name:
26
27 Signature:
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1550129.1 05303-699

STIPULATED PROTECTIVE ORDER