Cedarwood Young Company v. Bo Yang et al
Filing
37
PROTECTIVE ORDER by Magistrate Judge Alka Sagar re Stipulation for Protective Order 36 . (See Document for complete details) (afe)
1 ANDREW F. KIM (Bar No. 156533)
Akim@afklaw.com
2 LAW OFFICE OF ANDREW F. KIM
9018 Balboa Boulevard, Suite 552
3 Northridge, CA 91325
Telephone: (818) 216-5288
4
Attorneys for Plaintiff
5 CEDARWOOD-YOUNG COMPANY
DBA ALLAN COMPANY
6
KENNETH I. GROSS, ESQ. (State Bar No. 11738)
7 kgross@kigrosslaw.com
Kenneth I. Gross & Assoc.
8 849 S. Broadway, Ste. 504
Los Angeles, CA 90014
9 Telephone: (213) 627-0218
10 ALFRED I. CHAN, ESQ. (State Bar No. 216767)
achan@ahchanlaw.com
11 A.H. CHAN LAW FIRM, P.C.
805 West Duarte Road, Ste. 106
12 Arcadia, California 91007
Telephone: (626) 821-9094
13
Attorneys for Defendants
14 BO YANG and LING E.
15
16
UNITED STATES DISTRICT COURT
17
FOR THE CENTRAL DISTRICT OF CALIFORNIA
18
CEDARWOOD-YOUNG
19 COMPANY, a California
corporation,
20
21
Plaintiff,
v.
22 BO YANG, an individual, LING
YANG a.k.a. LING E a.k.a. LING E.
23 YANG, and DOES 2 through 10,
24
25
inclusive, et al.,
CASE NO.: 2:16 CV 3100 RGK (AS)
STIPULATION RE PROTECTIVE
ORDER AND ORDER THEREON
Trial: June 13, 2017
Pretrial Conf.: June 5, 2017
Motion Cut Off: April 5, 2017
Discovery Cut Off: March 23, 2017
Defendants.
26
27
28
STIPULATION RE PROTECTIVE ORDER AND [PROPOSED] ORDER THEREON
1
STIPULATION RE PROTECTIVE ORDER
2 1.
A.
3
Discovery in this action is likely to involve production of confidential,
PURPOSES AND LIMITATIONS
4 proprietary, or private information for which special protection from public
5 disclosure and from use for any purpose other than prosecuting this litigation may be
6 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter
7 the following Stipulated Protective Order. The parties acknowledge that this Order
8 does not confer blanket protections on all disclosures or responses to discovery and
9 that the protection it affords from public disclosure and use extends only to the
10 limited information or items that are entitled to confidential treatment under the
11 applicable legal principles. The parties further acknowledge, as set forth in Section
12 12.3, below, that this Stipulated Protective Order does not entitle them to file
13 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures
14 that must be followed and the standards that will be applied when a party seeks
15 permission from the court to file material under seal.
16
B.
17
This action is likely to involve trade secrets, customer and pricing lists and
GOOD CAUSE STATEMENT
18 other valuable research, development, commercial, financial, technical and/or
19 proprietary information for which special protection from public disclosure and from
20 use for any purpose other than prosecution of this action is warranted. Such
21 confidential and proprietary materials and information consist of, among other things,
22 confidential business or financial information, information regarding confidential
23 business practices, or other confidential research, development, or commercial
24 information (including information implicating privacy rights of third parties),
25 information otherwise generally unavailable to the public, or which may be privileged
26 or otherwise protected from disclosure under state or federal statutes, court rules, case
27 decisions, or common law. Accordingly, to expedite the flow of information, to
28
1
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1 facilitate the prompt resolution of disputes over confidentiality of discovery
2 materials, to adequately protect information the parties are entitled to keep
3 confidential, to ensure that the parties are permitted reasonable necessary uses of such
4 material in preparation for and in the conduct of trial, to address their handling at the
5 end of the litigation, and serve the ends of justice, a protective order for such
6 information is justified in this matter. It is the intent of the parties that information
7 will not be designated as confidential for tactical reasons and that nothing be so
8 designated without a good faith belief that it has been maintained in a confidential,
9 non-public manner, and there is good cause why it should not be part of the public
10 record of this case.
11 2.
DEFINITIONS
12
2.1
Action: Cedarwood-Young Company, a California corporation, v. Bo
13 Yang, an individual, Ling Yang a.k.a. Ling E. Yang, and DOES 2 through 10,
14 inclusive, Case No. 2:16-CV 3100 RGK (ASx).
15
2.2
Challenging Party: a Party or Non-Party that challenges the
16 designation of information or items under this Order.
17
2.3
“CONFIDENTIAL” Information or Items: information (regardless of
18 how it is generated, stored or maintained) or tangible things that qualify for protection
19 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
20 Cause Statement.
21
2.4
Counsel: Outside Counsel of Record and House Counsel (as well as
22 their support staff).
23
2.5
Designating Party: a Party or Non-Party that designates information or
24 items that it produces in disclosures or in responses to discovery as
25 “CONFIDENTIAL.”
26
2.6
Disclosure or Discovery Material: all items or information, regardless of
27 the medium or manner in which it is generated, stored, or maintained (including,
28
2
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1 among other things, testimony, transcripts, and tangible things), that are produced or
2 generated in disclosures or responses to discovery in this matter.
3
2.7
Expert: a person with specialized knowledge or experience in a matter
4 pertinent to the litigation who has been retained by a Party or its counsel to serve as
5 an expert witness or as a consultant in this Action.
6
2.8
House Counsel: attorneys who are employees of a party to this Action.
7 House Counsel does not include Outside Counsel of Record or any other outside
8 counsel.
9
2.9
Non-Party: any natural person, partnership, corporation, association, or
10 other legal entity not named as a Party to this action.
11
2.10 Outside Counsel of Record: attorneys who are not employees of a party
12 to this Action but are retained to represent or advise a party to this Action and have
13 appeared in this Action on behalf of that party or are affiliated with a law firm which
14 has appeared on behalf of that party, and includes support staff.
15
2.11
Party: any party to this Action, including all of its officers, directors,
16 employees, consultants, retained experts, and Outside Counsel of Record (and their
17 support staffs).
18
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
19 Discovery Material in this Action.
20
2.13 Professional Vendors: persons or entities that provide litigation support
21 services (e.g., photocopying, videotaping, translating, preparing exhibits or
22 demonstrations, and organizing, storing, or retrieving data in any form or medium)
23 and their employees and subcontractors.
24
2.14
Protected Material: any Disclosure or Discovery Material that is
25 designated as “CONFIDENTIAL.”
26
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
27 from a Producing Party.
28
3
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1 3.
2
SCOPE
The protections conferred by this Stipulation and Order cover not only
3 Protected Material (as defined above), but also (1) any information copied or
4 extracted from Protected Material; (2) all copies, excerpts, summaries, or
5 compilations of Protected Material; and (3) any testimony, conversations, or
6 presentations by Parties or their Counsel that might reveal Protected Material.
7
Any use of Protected Material at trial shall be governed by the orders of the
8 trial judge. This Order does not govern the use of Protected Material at trial.
9 4.
10
DURATION
Even after final disposition of this litigation, the confidentiality obligations
11 imposed by this Order shall remain in effect until a Designating Party agrees
12 otherwise in writing or a court order otherwise directs. Final disposition shall be
13 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
14 or without prejudice; and (2) final judgment herein after the completion and
15 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
16 including the time limits for filing any motions or applications for extension of time
17 pursuant to applicable law.
18 5.
DESIGNATING PROTECTED MATERIAL
19
5.1
20
Each Party or Non-Party that designates information or items for protection
Exercise of Restraint and Care in Designating Material for Protection.
21 under 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.
27
28
4
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1
Mass, indiscriminate, or routinized designations are prohibited. Designations
2 that are shown to be clearly unjustified or that have been made for an improper
3 purpose (e.g., to unnecessarily encumber the case development process or to impose
4 unnecessary expenses and burdens on other parties) may expose the Designating
5 Party to sanctions.
6
If it comes to a Designating Party’s attention that information or items that it
7 designated for protection do not qualify for protection, that Designating Party must
8 promptly notify all other Parties that it is withdrawing the inapplicable designation.
9
5.2
Manner and Timing of Designations. Except as otherwise provided in
10 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
11 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
12 under this Order must be clearly so designated before the material is disclosed or
13 produced.
14
15
Designation in conformity with this Order requires:
(a)
for information in documentary form (e.g., paper or electronic
16
documents, but excluding transcripts of depositions or other pretrial or trial
17
proceedings), that the Producing Party affix at a minimum, the legend
18
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page
19
that contains protected material. If only a portion or portions of the material on
20
a page qualifies for protection, the Producing Party also must clearly identify
21
the protected portion(s) (e.g., by making appropriate markings in the margins).
22
A Party or Non-Party that makes original documents available for
23
inspection need not designate them for protection until after the inspecting
24
Party has indicated which documents it would like copied and produced.
25
During the inspection and before the designation, all of the material made
26
available for inspection shall be deemed “CONFIDENTIAL.” After the
27
inspecting Party has identified the documents it wants copied and produced, the
28
5
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1
Producing Party must determine which documents, or portions thereof, qualify
2
for protection under this Order. Then, before producing the specified
3
documents, the Producing Party must affix the “CONFIDENTIAL legend” to
4
each page that contains Protected Material. If only a portion or portions of the
5
material on a page qualifies for protection, the Producing Party also must
6
clearly identify the protected portion(s) (e.g., by making appropriate markings
7
in the margins).
8
(b)
9
10
for testimony given in depositions that the Designating Party
identify the Disclosure or Discovery Material on the record, before the close of
the deposition all protected testimony.
11
(c)
for information produced in some form other than documentary
12
and for any other tangible items, that the Producing Party affix in a prominent
13
place on the exterior of the container or containers in which the information is
14
stored the legend “CONFIDENTIAL.” If only a portion or portions of the
15
information warrants protection, the Producing Party, to the extent practicable,
16
shall identify the protected portion(s).
17
5.3
Inadvertent Failures to Designate. If timely corrected, an inadvertent
18 failure to designate qualified information or items does not, standing alone, waive the
19 Designating Party’s right to secure protection under this Order for such material.
20 Upon timely correction of a designation, the Receiving Party must make reasonable
21 efforts to assure that the material is treated in accordance with the provisions of this
22 Order.
23 6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
24
6.1
Timing of Challenges. Any Party or Non-Party may challenge a
25 designation of confidentiality at any time that is consistent with the Court’s
26 Scheduling Order.
27
6.2
Meet and Confer. The Challenging Party shall initiate the dispute
28
6
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1 resolution process under Local Rule 37.1 et seq.
2
6.3
The burden of persuasion in any such challenge proceeding shall be on
3 the Designating Party. Frivolous challenges, and those made for an improper purpose
4 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
5 expose the Challenging Party to sanctions. Unless the Designating Party has waived
6 or withdrawn the confidentiality designation, all parties shall continue to afford the
7 material in question the level of protection to which it is entitled under the Producing
8 Party’s designation until the Court rules on the challenge.
9 7.
10
ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is
11 disclosed or produced by another Party or by a Non-Party in connection with this
12 Action only for prosecuting, defending, or attempting to settle this Action. Such
13 Protected Material may be disclosed only to the categories of persons and under the
14 conditions described in this Order. When the Action has been terminated, a Receiving
15 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
16
Protected Material must be stored and maintained by a Receiving Party at a
17 location and in a secure manner that ensures that access is limited to the persons
18 authorized under this Order.
19
7.2
Disclosure of “CONFIDENTIAL” Information or Items. Unless
20 otherwise ordered by the court or permitted in writing by the Designating Party, a
21 Receiving Party may disclose any information or item designated
22 “CONFIDENTIAL” only to:
23
(a)
the Receiving Party’s Outside Counsel of Record in this Action,
24
as well as employees of said Outside Counsel of Record to whom it is
25
reasonably necessary to disclose the information for this Action;
26
27
(b)
the officers, directors, and employees (including House Counsel)
of the Receiving Party to whom disclosure is reasonably necessary for this
28
7
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1
2
Action;
(c)
Experts (as defined in this Order) of the Receiving Party to whom
3
disclosure is reasonably necessary for this Action and who have signed the
4
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
5
(d)
the court and its personnel;
6
(e)
court reporters and their staff;
7
(f)
professional jury or trial consultants, mock jurors, and
8
Professional Vendors to whom disclosure is reasonably necessary for this
9
Action and who have signed the “Acknowledgment and Agreement to Be
10
11
Bound” (Exhibit A);
(g)
the author or recipient of a document containing the information
12
or a custodian or other person who otherwise possessed or knew the
13
information;
14
(h)
during their depositions, witnesses, and attorneys for witnesses, in
15
the Action to whom disclosure is reasonably necessary provided: (1) the
16
deposing party requests that the witness sign the form attached as Exhibit 1
17
hereto; and (2) they will not be permitted to keep any confidential information
18
unless the parties so agree, and they sign the “Acknowledgment and
19
Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the
20
Designating Party or ordered by the court. Pages of transcribed deposition
21
testimony or exhibits to depositions that reveal Protected Material may be
22
separately bound by the court reporter and may not be disclosed to anyone
23
except as permitted under this Stipulated Protective Order; and
24
25
(i)
any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by the parties engaged in settlement discussions.
26
27
28
8
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1 8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
2
OTHER LITIGATION
3
If a Party is served with a subpoena or a court order issued in other litigation
4 that compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL,” that Party must:
5
6
7
(a)
notification shall include a copy of the subpoena or court order;
8
9
promptly notify in writing the Designating Party. Such
(b)
promptly notify in writing the party who caused the subpoena or
order to issue in the other litigation that some or all of the material covered by
10
the subpoena or order is subject to this Protective Order. Such notification shall
11
include a copy of this Stipulated Protective Order; and
12
13
(c)
cooperate with respect to all reasonable procedures sought to be
pursued by the Designating Party whose Protected Material may be affected.
14
If the Designating Party timely seeks a protective order, the Party served
15 with the subpoena or court order shall not produce any information designated in this
16 action as “CONFIDENTIAL” before a determination by the court from which the
17 subpoena or order issued, unless the Party has obtained the Designating Party’s
18 permission. The Designating Party shall bear the burden and expense of seeking
19 protection in that court of its confidential material and nothing in these provisions
20 should be construed as authorizing or encouraging a Receiving Party in this Action to
21 disobey a lawful directive from another court.
22 9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
23
PRODUCED IN THIS LITIGATION
24
(a)
The terms of this Order are applicable to information produced by a
25 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
26 produced by Non-Parties in connection with this litigation is protected by the
27 remedies and relief provided by this Order. Nothing in these provisions should be
28
9
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1 construed as prohibiting a Non-Party from seeking additional protections.
2
(b)
In the event that a Party is required, by a valid discovery request, to
3 produce a Non-Party’s confidential information in its possession, and the Party is
4 subject to an agreement with the Non-Party not to produce the Non-Party’s
5 confidential information, then the Party shall:
6
(1)
promptly notify in writing the Requesting Party and the Non-Party
7
that some or all of the information requested is subject to a confidentiality
8
agreement with a Non-Party;
9
(2)
promptly provide the Non-Party with a copy of the Stipulated
10
Protective Order in this Action, the relevant discovery request(s), and a
11
reasonably specific description of the information requested; and
12
(3)
make the information requested available for inspection by the
13
Non-Party, if requested.
14
(c)
If the Non-Party fails to seek a protective order from this court within 14
15 days of receiving the notice and accompanying information, the Receiving Party may
16 produce the Non-Party’s confidential information responsive to the discovery request.
17 If the Non-Party timely seeks a protective order, the Receiving Party shall not
18 produce any information in its possession or control that is subject to the
19 confidentiality agreement with the Non-Party before a determination by the court.
20 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
21 of seeking protection in this court of its Protected Material.
22 10.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
23
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
24 Protected Material to any person or in any circumstance not authorized under this
25 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
26 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
27 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
28
10
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1 persons to whom unauthorized disclosures were made of all the terms of this Order,
2 and (d) request such person or persons to execute the “Acknowledgment and
3 Agreement to Be Bound” that is attached hereto as Exhibit A.
4 11.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
5
PROTECTED MATERIAL
6
When a Producing Party gives notice to Receiving Parties that certain
7 inadvertently produced material is subject to a claim of privilege or other protection,
8 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
9 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
10 may be established in an e-discovery order that provides for production without prior
11 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
12 parties reach an agreement on the effect of disclosure of a communication or
13 information covered by the attorney-client privilege or work product protection, the
14 parties may incorporate their agreement in the stipulated protective order submitted to
15 the court.
16 12.
17
MISCELLANEOUS
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
18 person to seek its modification by the Court in the future.
19
12.2 Right to Assert Other Objections. By stipulating to the entry of this
20 Protective Order no Party waives any right it otherwise would have to object to
21 disclosing or producing any information or item on any ground not addressed in this
22 Stipulated Protective Order. Similarly, no Party waives any right to object on any
23 ground to use in evidence of any of the material covered by this Protective Order.
24
12.3 Filing Protected Material. A Party that seeks to file under seal any
25 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
26 only be filed under seal pursuant to a court order authorizing the sealing of the
27 specific Protected Material at issue. If a Party's request to file Protected Material
28
11
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1 under seal is denied by the court, then the Receiving Party may file the information in
2 the public record unless otherwise instructed by the court.
3 13.
FINAL DISPOSITION
4
After the final disposition of this Action, as defined in paragraph 4, within 60
5 days of a written request by the Designating Party, each Receiving Party must return
6 all Protected Material to the Producing Party or destroy such material. As used in this
7 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
8 summaries, and any other format reproducing or capturing any of the Protected
9 Material. Whether the Protected Material is returned or destroyed, the Receiving
10 Party must submit a written certification to the Producing Party (and, if not the same
11 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
12 (by category, where appropriate) all the Protected Material that was returned or
13 destroyed and (2)affirms that the Receiving Party has not retained any copies,
14 abstracts, compilations, summaries or any other format reproducing or capturing any
15 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
16 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
17 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
18 reports, attorney work product, and consultant and expert work product, even if such
19 materials contain Protected Material. Any such archival copies that contain or
20 constitute Protected Material remain subject to this Protective Order as set forth in
21 Section 4 (DURATION).
22 / /
23 / /
24 / /
25 / /
26 / /
27 / /
28
12
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1 14.
CONTEMPT
2
Any violation of this Order may be punished by any and all appropriate
3 measures including, without limitation, contempt proceedings and/or monetary
4 sanctions.
5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6
DATED: December 8, 2016
7
LAW OFFICE OF ANDREW F. KIM, ESQ.
P.C.
8
By: _______________________________
Andrew F. Kim
ATTORNEYS FOR PLAINTIF
CEDARWOOD-YOUNG COMPANY
9
10
11
12
13
DATED: December 8, 2016
KENNETH I. GROSS & ASSOCIATES
14
By:
/s/ Kenneth I. Gross
Kenneth I. Gross
ATTORNEYS FOR DEFENDANTS
BO YANG and LING E.
15
16
17
18
DATED: December 8, 2016
A.H. CHAN LAW FIRM
19
20
21
22
By: /S/ Alfred H. Chan
Alfred H. Chan
ATTORNEYS FOR DEFENDANTS
BO YANG and LING E.
23
24
25
FOR GOOD CAUSE SHOWN, IT IS ORDERED.
DATED: ____________________
December 9, 2016
26 _____________________________________
/s/
27 HONORABLE ALKA SAGAR
28
UNITED STATES DISTRICT JUDGE
13
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
1
EXHIBIT A
2
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
I, ______________________________________[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 the
7 Central District of California on [date] in the case of Cedarwood-Young Company, a
8 California corporation, v. Bo Yang, an individual, Ling Yang a.k.a. Ling E. Yang,
9 and DOES 2 through 10, inclusive, Case No. 2:16-CV 3100 RGK (ASx). I agree to
10 comply with and to be bound by all the terms of this Stipulated Protective Order and I
11 understand and acknowledge that failure to so comply could expose me to sanctions
12 and punishment in the nature of contempt. I solemnly promise that I will not disclose
13 in any manner any information or item that is subject to this Stipulated Protective
14 Order to any person or entity except in strict compliance with the provisions of this
15 Order.
16
I further agree to submit to the jurisdiction of the United States District Court
17 for the Central District of California for the purpose of enforcing the terms of this
18 Stipulated Protective Order, even if such enforcement proceedings occur after
19 termination of this action.
20
I hereby appoint ______________________ [print or type full name] of
21 _____________________________ [print or type full address and telephone number]
22 as my California agent for service of process in connection with this action or any
23 proceedings related to enforcement of this Stipulated Protective Order.
24
Date: ______________________________
25
City and State where sworn and signed: ________________________
26
Printed name: ________________________________
27
Signature: __________________________________
28
STIPULATION RE PROTECTIVE ORDER AND [PROPOSED] ORDER THEREON
1
2
ATTESTATION OF SIGNATURE
I, Andrew F. Kim, am the ECF User whose ID and Password were used to
3 electronically file this Stipulation to Extend Time to Respond to Amended Complaint.
4 Pursuant to Central District of California Local Rule 5-4.3.4(a)(2), I hereby attest that
5 all other signatories listed, and on whose behalf this filing is submitted, concur in the
6 content of this filing and have authorized the electronic filing thereof.
7
8
9
Andrew F. Kim
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1
STIPULATION RE PROECTIVE ORDER AND [PROPOSED] ORDER THEREON
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?