Anns Trading Company, Inc. v. Kanma, Inc.

Filing 27

STIPULATED PROTECTIVE ORDER by Magistrate Judge Rozella A. Oliver. Discovery in this action is likely to involve production of confidential, proprietary or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. 26 (SEE ORDER FOR FURTHER DETAILS) (gr)

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1 2 3 4 5 CHAIM J. WOOLF, SBN 236957 WOOLF & NACHIMSON, LLP 15300 Ventura Blvd., Suite 214 Sherman Oaks, CA 91403 Tel: (310) 474-8776; Fax: (310) 919-3037 E-Mail: 03/08/17 G R Attorneys for Defendant, KANMA, INC. 6 LEE ANAV CHUNG WHITE KIM 7 RUGER & RICHTER LLP Bub-Joo S. Lee (State Bar No. 159002) 8 Anna Novruzyan (State Bar No. 278427) 9 10 The Biltmore Court Building 520 S. Grand Avenue, Suite 1070 11 Los Angeles, CA 90071 Tel. (213) 341-1602 | Fax. (213) 402-8635 12 13 Attorneys for Plaintiff ANN’S TRADING COMPANY, INC. 14 15 UNITED STATES DISTRICT COURT 16 CENTRAL DISTRICT OF CALIFORNIA 17 18 ANNS TRADING COMPANY, INC. 19 20 21 22 23 Case No.: 2:16-CV-03585-AB-RAOx Plaintiff, [Assigned to the Hon. Judge Andre’ Birotte, Jr.] v. STIPULATED PROTECTIVE ORDER KANMA, INC., Defendant. 24 25 26 27 28 1 PROTECTIVE ORDER 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 4 5 proprietary or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. 6 7 Accordingly, the parties hereby stipulate to and petition the Court to enter the 8 following Stipulated Protective Order. The parties acknowledge that this Order does 9 not confer blanket protections on all disclosures or responses to discovery and that the 10 11 protection it affords from public disclosure and use extends only to the limited 12 information or items that are entitled to confidential treatment under the applicable 13 legal principles.1 14 15 B. GOOD CAUSE STATEMENT 16 This action is likely to involve trade secrets, customer and pricing lists and 17 other valuable research, development, commercial, financial, or proprietary 18 19 information for which special protection from public disclosure and from use for any 20 purpose other than prosecution of this action is warranted. Such confidential and 21 22 proprietary materials and information consist of, among other things, confidential 23 business or financial information, information regarding confidential business 24 practices, or other confidential or commercial information (including information 25 26 implicating privacy rights of third parties), information otherwise generally 27 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Rozella A. Oliver’s Procedures. 1 28 2 PROTECTIVE ORDER 1 unavailable to the public, or which may be privileged or otherwise protected from 2 disclosure under state or federal statutes, court rules, case decisions, or common law. 3 Specifically, Plaintiff and Defendant are competitors of one another and access to 4 5 each parties pricing of good and client lists could create future unfair advantages that 6 could materially damage each other’s business .Accordingly, to expedite the flow of 7 information, to facilitate the prompt resolution of disputes over confidentiality of 8 9 discovery materials, to adequately protect information the parties are entitled to keep 10 confidential, to ensure that the parties are permitted reasonable necessary uses of such 11 material in preparation for and in the conduct of trial, to address their handling at the 12 13 end of the litigation, and serve the ends of justice, a protective order for such 14 information is justified in this matter. It is the intent of the parties that information 15 16 will not be designated as confidential for tactical reasons and that nothing be so 17 designated without a good faith belief that it has been maintained in a confidential, 18 non-public manner, and there is good cause why it should not be part of the public 19 20 record of this case. 21 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 22 SEAL 23 24 The parties further acknowledge, as set forth in Section 12.3, below, that this 25 Stipulated Protective Order does not entitle them to file confidential information under 26 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 27 28 3 PROTECTIVE ORDER 1 standards that will be applied when a party seeks permission from the court to file 2 material under seal. 3 There is a strong presumption that the public has a right of access to judicial 4 5 proceedings and records in civil cases. In connection with non-dispositive motions, 6 good cause must be shown to support a filing under seal. See Kamakana v. City and 7 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 8 9 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 10 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 11 cause showing), and a specific showing of good cause or compelling reasons with 12 13 proper evidentiary support and legal justification, must be made with respect to 14 Protected Material that a party seeks to file under seal. The parties’ mere designation 15 16 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the 17 submission of competent evidence by declaration, establishing that the material sought 18 to be filed under seal qualifies as confidential, privileged, or otherwise protectable— 19 20 21 22 constitute good cause. Further, if a party requests sealing related to a dispositive motion or trial, then compelling reasons, not only good cause, for the sealing must be shown, and the relief 23 24 sought shall be narrowly tailored to serve the specific interest to be protected. See 25 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item 26 or type of information, document, or thing sought to be filed or introduced under seal 27 28 in connection with a dispositive motion or trial, the party seeking protection must 4 PROTECTIVE ORDER 1 articulate compelling reasons, supported by specific facts and legal justification, for 2 the requested sealing order. Again, competent evidence supporting the application to 3 file documents under seal must be provided by declaration. 4 5 6 7 Any document that is not confidential, privileged, or otherwise protectable in its entirety will not be filed under seal if the confidential portions can be redacted. If documents can be redacted, then a redacted version for public viewing, omitting only 8 9 10 11 the confidential, privileged, or otherwise protectable portions of the document, shall be filed. Any application that seeks to file documents under seal in their entirety should include an explanation of why redaction is not feasible. 12 13 14 15 16 17 18 2. DEFINITIONS 2.1 Action: This pending federal lawsuit. 2.2 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 19 20 how it is generated, stored or maintained) or tangible things that qualify for protection 21 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 22 Cause Statement. 23 24 25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 26 27 28 5 PROTECTIVE ORDER 1 2 3 2.5 Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 4 5 6 7 2.6 Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or 8 9 10 11 generated in disclosures or responses to discovery in this matter. 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an 12 13 14 15 16 17 18 expert witness or as a consultant in this Action. 2.8 House Counsel: attorneys who are employees of a party to this Action. House Counsel does not include Outside Counsel of Record or any other outside counsel. 2.9 Non-Party: any natural person, partnership, corporation, association or 19 20 21 22 other legal entity not named as a Party to this action. 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this Action but are retained to represent or advise a party to this Action and have 23 24 25 appeared in this Action on behalf of that party or are affiliated with a law firm that has appeared on behalf of that party, and includes support staff. 26 27 28 6 PROTECTIVE ORDER 1 2 3 2.11 Party: any party to this Action, including all of its officers, directors, employees, consultants, retained experts, and Outside Counsel of Record (and their support staffs). 4 5 6 7 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 2.13 Professional Vendors: persons or entities that provide litigation support 8 9 10 11 services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors. 12 13 14 15 16 2.14 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 17 from a Producing Party. 18 3. SCOPE 19 20 The protections conferred by this Stipulation and Order cover not only 21 Protected Material (as defined above), but also (1) any information copied or extracted 22 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 23 24 25 26 Protected Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the trial 27 28 judge. This Order does not govern the use of Protected Material at trial. 7 PROTECTIVE ORDER 1 /// 2 4. DURATION Once a case proceeds to trial, information that was designated as 3 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 4 5 as an exhibit at trial becomes public and will be presumptively available to all 6 members of the public, including the press, unless compelling reasons supported by 7 specific factual findings to proceed otherwise are made to the trial judge in advance of 8 9 10 11 the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing documents produced in discovery from “compelling reasons” standard when merits-related documents are part of court record). Accordingly, the terms of 12 13 this protective order do not extend beyond the commencement of the trial. 14 5. DESIGNATING PROTECTED MATERIAL 15 16 17 18 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-Party that designates information or items for protection under this Order must take care to limit any such designation to specific material that 19 20 qualifies under the appropriate standards. The Designating Party must designate for 21 protection only those parts of material, documents, items or oral or written 22 communications that qualify so that other portions of the material, documents, items 23 24 25 26 or communications for which protection is not warranted are not swept unjustifiably within the ambit of this Order. Mass, indiscriminate or routinized designations are prohibited. Designations 27 28 that are shown to be clearly unjustified or that have been made for an improper 8 PROTECTIVE ORDER 1 purpose (e.g., to unnecessarily encumber the case development process or to impose 2 unnecessary expenses and burdens on other parties) may expose the Designating Party 3 to sanctions. 4 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 9 10 11 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 12 13 under this Order must be clearly so designated before the material is disclosed or 14 produced. 15 16 17 18 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic documents, but excluding transcripts of depositions or other pretrial or trial 19 20 proceedings), that the Producing Party affix at a minimum, the legend 21 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page 22 that contains protected material. If only a portion of the material on a page 23 24 25 26 qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). A Party or Non-Party that makes original documents available for inspection 27 28 9 PROTECTIVE ORDER 1 need not designate them for protection until after the inspecting Party has indicated 2 which documents it would like copied and produced. During the inspection and before 3 the designation, all of the material made available for inspection shall be deemed 4 5 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 6 copied and produced, the Producing Party must determine which documents, or 7 portions thereof, qualify for protection under this Order. Then, before producing the 8 9 10 11 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page that contains Protected Material. If only a portion of the material on a page qualifies for protection, the Producing Party also must clearly identify the 12 13 14 15 16 17 18 protected portion(s) (e.g., by making appropriate markings in the margins). (b) for testimony given in depositions that the Designating Party identifies the Disclosure or Discovery Material on the record, before the close of the deposition all protected testimony. (c) for information produced in some form other than documentary and for any 19 20 other tangible items, that the Producing Party affix in a prominent place on the 21 exterior of the container or containers in which the information is stored the legend 22 “CONFIDENTIAL.” If only a portion or portions of the information warrants 23 24 25 26 protection, the Producing Party, to the extent practicable, shall identify the protected portion(s). 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 27 28 failure to designate qualified information or items does not, standing alone, waive the 10 PROTECTIVE ORDER 1 Designating Party’s right to secure protection under this Order for such material. 2 Upon timely correction of a designation, the Receiving Party must make reasonable 3 efforts to assure that the material is treated in accordance with the provisions of this 4 5 Order. 6 6. 7 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 8 9 10 designation of confidentiality at any time that is consistent with the Court’s Scheduling Order. 11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 12 13 resolution process under Local Rule 37.1 et seq. 14 15 16 6.3 The burden of persuasion in any such challenge proceeding shall be on the Designating Party. Frivolous challenges, and those made for an improper purpose 17 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 18 expose the Challenging Party to sanctions. Unless the Designating Party has waived or 19 20 withdrawn the confidentiality designation, all parties shall continue to afford the 21 material in question the level of protection to which it is entitled under the Producing 22 Party’s designation until the Court rules on the challenge. 23 24 25 26 /// 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 27 28 disclosed or produced by another Party or by a Non-Party in connection with this 11 PROTECTIVE ORDER 1 Action only for prosecuting, defending or attempting to settle this Action. Such 2 Protected Material may be disclosed only to the categories of persons and under the 3 conditions described in this Order. When the Action has been terminated, a Receiving 4 5 6 7 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). Protected Material must be stored and maintained by a Receiving Party at a location and in a secure manner that ensures that access is limited to the persons 8 9 10 11 authorized under this Order. 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the court or permitted in writing by the Designating Party, a 12 13 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 14 only to: 15 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 17 employees of said Outside Counsel of Record to whom it is reasonably necessary to 18 disclose the information for this Action; 19 20 (b) the officers, directors, and employees (including House Counsel) of the 21 Receiving Party to whom disclosure is reasonably necessary for this Action; 22 (c) Experts (as defined in this Order) of the Receiving Party to whom 23 24 25 26 disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (d) the court and its personnel; 27 28 (e) court reporters and their staff; 12 PROTECTIVE ORDER (f) professional jury or trial consultants, mock jurors, and Professional Vendors 1 2 3 to whom disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) the author or recipient of a document containing the information or a 5 6 custodian or other person who otherwise possessed or knew the information; 7 (h) during their depositions, witnesses, and attorneys for witnesses, in the 8 9 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 10 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 11 not be permitted to keep any confidential information unless they sign the 12 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 14 by the Designating Party or ordered by the court. Pages of transcribed deposition 15 16 testimony or exhibits to depositions that reveal Protected Material may be separately 17 bound by the court reporter and may not be disclosed to anyone except as permitted 18 under this Stipulated Protective Order; and 19 (i) any mediator or settlement officer, and their supporting personnel, mutually 20 21 agreed upon by any of the parties engaged in settlement discussions. 22 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 23 24 25 26 IN OTHER LITIGATION If a Party is served with a subpoena or a court order issued in other litigation that compels disclosure of any information or items designated in this Action as 27 28 “CONFIDENTIAL,” that Party must: 13 PROTECTIVE ORDER (a) promptly notify in writing the Designating Party. Such notification shall 1 2 include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or order to 4 5 issue in the other litigation that some or all of the material covered by the subpoena or 6 order is subject to this Protective Order. Such notification shall include a copy of this 7 Stipulated Protective Order; and 8 (c) cooperate with respect to all reasonable procedures sought to be pursued by 9 10 11 the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with the subpoena or court 12 13 order shall not produce any information designated in this action as 14 “CONFIDENTIAL” before a determination by the court from which the subpoena or 15 16 order issued, unless the Party has obtained the Designating Party’s permission. The 17 Designating Party shall bear the burden and expense of seeking protection in that 18 court of its confidential material and nothing in these provisions should be construed 19 20 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 21 directive from another court. 22 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 23 24 25 26 PRODUCED IN THIS LITIGATION (a) The terms of this Order are applicable to information produced by a NonParty in this Action and designated as “CONFIDENTIAL.” Such information 27 28 produced by Non-Parties in connection with this litigation is protected by the 14 PROTECTIVE ORDER 1 remedies and relief provided by this Order. Nothing in these provisions should be 2 construed as prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to produce 4 5 a Non-Party’s confidential information in its possession, and the Party is subject to an 6 agreement with the Non-Party not to produce the Non-Party’s confidential 7 information, then the Party shall: 8 9 10 11 (1) promptly notify in writing the Requesting Party and the Non-Party that some or all of the information requested is subject to a confidentiality agreement with a Non-Party; 12 13 (2) promptly provide the Non-Party with a copy of the Stipulated 14 Protective Order in this Action, the relevant discovery request(s), and a 15 16 17 18 reasonably specific description of the information requested; and (3) make the information requested available for inspection by the NonParty, if requested. 19 20 (c) If the Non-Party fails to seek a protective order from this court within 14 21 days of receiving the notice and accompanying information, the Receiving Party may 22 produce the Non-Party’s confidential information responsive to the discovery request. 23 24 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 25 any information in its possession or control that is subject to the confidentiality 26 agreement with the Non-Party before a determination by the court. Absent a court 27 28 15 PROTECTIVE ORDER 1 order to the contrary, the Non-Party shall bear the burden and expense of seeking 2 protection in this court of its Protected Material. 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 5 6 7 Protected Material to any person or in any circumstance not authorized under this Stipulated Protective Order, the Receiving Party must immediately (a) notify in 8 9 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 10 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 11 persons to whom unauthorized disclosures were made of all the terms of this Order, 12 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 16 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 17 PROTECTED MATERIAL 18 When a Producing Party gives notice to Receiving Parties that certain 19 20 inadvertently produced material is subject to a claim of privilege or other protection, 21 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 22 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 23 24 may be established in an e-discovery order that provides for production without prior 25 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 26 parties reach an agreement on the effect of disclosure of a communication or 27 28 information covered by the attorney-client privilege or work product protection, the 16 PROTECTIVE ORDER 1 parties may incorporate their agreement in the stipulated protective order submitted to 2 the court. 3 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 5 6 person to seek its modification by the Court in the future. 7 12.2 Right to Assert Other Objections. By stipulating to the entry of this 8 9 10 11 Protective Order, no Party waives any right it otherwise would have to object to disclosing or producing any information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no Party waives any right to object on any 12 13 ground to use in evidence of any of the material covered by this Protective Order. 14 15 16 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected Material must comply with Local Civil Rule 79-5. Protected Material may 17 only be filed under seal pursuant to a court order authorizing the sealing of the 18 specific Protected Material at issue. If a Party’s request to file Protected Material 19 20 under seal is denied by the court, then the Receiving Party may file the information in 21 the public record unless otherwise instructed by the court. 22 13. FINAL DISPOSITION 23 24 After the final disposition of this Action, as defined in paragraph 4, within 60 25 days of a written request by the Designating Party, each Receiving Party must return 26 all Protected Material to the Producing Party or destroy such material. As used in this 27 28 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 17 PROTECTIVE ORDER 1 summaries, and any other format reproducing or capturing any of the Protected 2 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 3 must submit a written certification to the Producing Party (and, if not the same person 4 5 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 6 category, where appropriate) all the Protected Material that was returned or destroyed 7 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 8 9 10 11 compilations, summaries or any other format reproducing or capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 12 13 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 14 attorney work product, and consultant and expert work product, even if such materials 15 16 contain Protected Material. Any such archival copies that contain or constitute 17 Protected Material remain subject to this Protective Order as set forth in Section 4 18 (DURATION). 19 20 14. VIOLATION 21 Any violation of this Order may be punished by appropriate measures including, 22 without limitation, contempt proceedings and/or monetary sanctions. 23 24 /// 25 /// 26 /// 27 28 /// 18 PROTECTIVE ORDER 1 /// 2 /// 3 /// 4 5 /// 6 /// 7 /// 8 9 10 /// IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 11 12 13 DATED:03/06/2017 WOOLF & NACHIMSON, LLP 14 15 By: /s/ Chaim J. Woolf Chaim J. Woolf Attorneys for Defendant, 16 17 18 19 20 DATED:03/06/2017 Lee Anav Chung White & Kim LLP 21 22 By: /s/ Bub Joo S. Lee Bub Joo Lee Attorneys for Plaintiff, 23 24 25 26 ATTESTATION I, Chaim J. Woolf, am the ECF User whose ID and password are being used to file this Protective Order. In compliance with Local Rule 5-4.3.4, I hereby attest that Bub-Joo S. Lee has concurred in the content of the Protective Order and has authorized this filing. 27 28 19 PROTECTIVE ORDER 1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. DATED: March 8, 2017 2 3 4 5 6 ______________________________________________ HON. ROZELLA A. OLIVER 7 United States Magistrate Judge 8 9 10 11 12 13 14 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 15 16 17 18 I, _____________________________ [print or type full name], of ______________________________________________________________ [print or type full address], declare under penalty of perjury that I have read in its entirety and 19 20 understand the Stipulated Protective Order that was issued by the United States 21 District Court for the Central District of California on [date] in the case of Anns 22 Trading Company v. Kanma, Inc. Case No.: 2:16-CV-03585-AB-RAOx. I agree to comply 23 24 with and to be bound by all the terms of this Stipulated Protective Order and I 25 understand and acknowledge that failure to so comply could expose me to sanctions 26 and punishment in the nature of contempt. I solemnly promise that I will not disclose 27 28 in any manner any information or item that is subject to this Stipulated Protective 20 PROTECTIVE ORDER 1 Order to any person or entity except in strict compliance with the provisions of this 2 Order. I further agree to submit to the jurisdiction of the United States District Court 3 for the Central District of California for enforcing the terms of this Stipulated 4 5 Protective Order, even if such enforcement proceedings occur after termination of this 6 action. I hereby appoint __________________________ [print or type full name] of 7 __________________________________________________ [print or type full 8 9 10 11 address and telephone number] as my California agent for service of process in connection with this action or any proceedings related to enforcement of this Stipulated Protective Order. 12 13 Date: ______________________________________ 14 City and State where sworn and signed: _________________________________ 15 16 17 Printed name: _______________________________ Signature: __________________________________ 18 19 20 21 22 23 24 25 26 27 28 21 PROTECTIVE ORDER

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