Zelouf West Ltd. v. Shoreline Wear, Inc. et al

Filing 27

ORDER GRANTING STIPULATED PROTECTIVE ORDER by Magistrate Judge Alicia G. Rosenberg re Stipulation for Protective Order, 26 . ***** SEE ORDER FOR DETAILS. ***** NOTE CHANGES MADE BY THE COURT. ***** (mp)

ease 2:1116-cv-04689-RGK-A

Document 26-1 Filed 02/06/17

~e 1 of 16 Page ID #:123.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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Case No. 2:16-cv-04689-RGK(AGE)

ZELOUF WEST LTD., a California
12 Corporation,
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Plaintiff,
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Assigned to: Hon. R. Gary Klausner
United States District Judge
Referred to: Hon. Alicia G. Rosenberg
United States Magistrate Judge

vs.

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SHORELINE WEAR,INC., a New
17 York Corporation; ZULILY,LLC,a
Delaware Limited Liability Company;
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and DOES 1 through 10,
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Defendants.
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0

PROPOSED]ORDER GRANTING
[
STIPULATED PROTECTIVE
ORDER

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-i[PROPOSED]ORDER GRANTING STIPULATED PROTECTIVE ORD

~~ase 2k~.6-cv-04689-RGK-A

Document 26-1 Filed 02/06/17

~e 2 of 16 Page ID #:124.

Upon consideration of the Stipulated Protective Order dated February 6, 2017

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between Plaintiff Zelouf West Ltd.("Plaintiff or "Zelou~') and Defendants

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Shoreline Wear, Inc.("Shoreline") and Zulily, LLC ("Zulily")(Shoreline and Zulily

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collectively,"Defendants"), and finding good cause thereon,
IT IS HEREBY ORDERED that the terms of the Stipulated Protective

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Order shall govern the handling and disclosure of documents, things, and

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information produced in this Action as follows:

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1.

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A. PURPOSES AND LIMITATIONS
Discovery in this action is likely to involve production of confidential,

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proprietary or private information for which special protection from public

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disclosure and from use for any purpose other than prosecuting this litigation may

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be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

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enter the following Stipulated Protective Order. The parties acknowledge that this

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Order does not confer blanket protections on all disclosures or responses to

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discovery and that the protection it affords from public disclosure and use extends

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only to the limited information or items that are entitled to confidential treatment

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under the applicable legal principles.

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B. GOOD CAUSE STATEMENT

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

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other valuable research, development, commercial, financial, technical and/or

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proprietary information for which special protection from public disclosure during

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discovery and from use for any purpose other than prosecution of this action may be

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warranted. Such confidential and proprietary materials and information consist of,

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among other things, confidential business or financial information, information

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regarding confidential business practices, or other confidential research,

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development, or commercial information (including information implicating privacy

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rights of third parties), information otherwise generally unavailable to the public, or
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Case 2116-cv-04689-RGK-A

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which may be privileged or otherwise protected from disclosure under state or

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federal statutes, court rules, case decisions, or common law. Accordingly, to

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expedite the flow of information, to facilitate the prompt resolution of disputes over

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confidentiality of discovery materials, to adequately protect information the parties

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are entitled to keep confidential, to ensure that the parties are permitted reasonable

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necessary uses of such material in preparation for and in the conduct of trial, to

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address their handling at the end of the litigation, and serve the ends ofjustice, a

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protective order for such information is justified in this matter. It is the intent of the

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parties that information will not be designated as confidential for tactical reasons

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and that nothing be so designated without a good faith belief that it has been

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maintained in a confidential, non-public manner, and there is good cause why it

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should not be part of the public record of this case. The parties understand and

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acknowledge that this Protective Order does not govern the use of materials at trial.

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Any motions for protective order or requests that documents be maintained under

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seal must be made to the judicial officer handling the trial.

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C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

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The parties further acknowledge, as set forth in Section 12.3, below, that this

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Stipulated Protective Order does not entitle them to file confidential information

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under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed

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and the standards that will be applied when a party seeks permission from the court

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to file material under seal.

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There is a strong presumption that the public has a right of access to judicial

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proceedings and records in civil cases. In connection with non-diapositive motions,

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good cause must be shown to support a filing under seal. See Kamakana v. City and

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County ofHonolulu, 447 F.3d 1172, 1176(9th Cir. 2006), Phillips v. Gen. Motors

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COYp•, 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sonv Electrics,

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Inc., 187 F.R.D. 576, 577(E.D. Wis. 1999)(even stipulated protective orders
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[PROPOSED]ORDER GRANTING STIPULATED PROTECTIVE ORDER

Case

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'_6-cv-04689-RGK-AG.. Document 26-1 Filed 02/06/17 P

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require good cause showing), and a specific showing of good cause or compelling
reasons with proper evidentiary support and legal justification, must be made with
respect to Protected Material that a party seeks to file under seal. The parties' mere
designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
without the submission of competent evidence by declaration, establishing that the
material sought to be filed under seal qualifies as confidential, privileged, or
otherwise protectable---constitute good cause.

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Further, if a party requests sealing related to

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compelling reasons, not only good cause, for the sealing must be shown, and the
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or introduced
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S~2o1~'12 J each item or type of information, document, or thing sought to be filed
13 under seal in connection with a dispositive motion or trial, the party seeking
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protection must articulate compelling reasons, supported by specific facts and legal
ing
justification, for the requested sealing order. Again, competent evidence support
the application to file documents under seal must be provided by declaration.
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

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only the confidential, privileged, or otherwise protectable portions of the document,
shall be filed. Any application that seeks to file documents under seal in their

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entirety should include an explanation of why redaction is not feasible.

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DEFINITIONS

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Action: This pending federal lawsuit.

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Challen~g Party: a Party or Non-Party that challenges the

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designation of information or items under this Order.
.3.1 "CONFIDENTIAL" Information or Items: information (regardless of
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how it is generated, stored or maintained) or tangible things that qualify for

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protection under Federal Rule of Civil Procedure 26(c), and as specified above in

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the Good Cause Statement.

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.3.2 "HIGHLY CONFIDENTIAL - AEO"Information or Items:
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information that constitutes a trade secret of the Designating Party.
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Counsel: Outside Counsel of Record and House Counsel(as well as

their support staff.
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.5

Desi gnating Party: a Party or Non-Party that designates information or

items that it produces in disclosures or in responses to discovery as
CONFIDENTIAL" or "HIGHLY CONFIDENTIAL — AEO".
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.6

Disclosure or Discovery Material: all items or information, regardless

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of the medium or manner in which it is generated, stored, or maintained (including,

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among other things, testimony, transcripts, and tangible things), that are produced or

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generated in disclosures or responses to discovery in this matter.

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

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pertinent to the litigation who has been retained by a Party or its counsel to serve as

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an expert witness or as a consultant in this Action.

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

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House Counsel does not include Outside Counsel of Record or any other outside

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counsel.

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

other legal entity not named as a Party to this action.
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.10 Outside Counsel of Record: attorneys who are not employees of a

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party to this Action but are retained to represent or advise a party to this Action and

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have appeared in this Action on behalf of that party or are affiliated with a law firm

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that has appeared on behalf of that party, and includes support staff.

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.11 Party: any party to this Action, including all of its officers, directors,
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employees, consultants, retained experts, and Outside Counsel of Record(and their
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support staffs).

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Document 26-1 Filed 02/06/17

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.12 Producin~rtv: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.

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.13 Professional Vendors: persons or entities that provide litigation

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support services (e.g., photocopying, videotaping, translating, preparing exhibits or

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demonstrations, and organizing, storing, or retrieving data in any form or medium)

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and their employees and subcontractors.

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.14 Protected Material: any Disclosure or Discovery Material that is

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designated as"CONFIDENTIAL" or "HIGHLY CONFIDENTIAL — AEO".

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.15 Receivin~rtv_: a Party that receives Disclosure or Discovery

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Material from a Producing Party.

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3.

SCOPE

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The protections conferred by this Stipulation and Order cover not only

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Protected Material(as defined above), but also (1) any information copied or

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extracted from Protected Material;(2) all copies, excerpts, summaries, or

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compilations of Protected Material; and (3)any testimony, conversations, or

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presentations by Parties or their Counsel that might reveal Protected Material.

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Any use of Protected Material at trial shall be governed by the orders of the
trial judge. This Order does not govern the use of Protected Material at trial.

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DURATION
Once a case proceeds to trial, information that was designated as

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CONFIDENTIAL or maintained pursuant to this protective order used or introduced

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as an e~ibit at trial becomes public and will be presumptively available to all

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members of the public, including the press, unless compelling reasons supported by

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specific factual findings to proceed otherwise are made to the trial judge in advance

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of the trial. See Kamakana,447 F.3d at 1180-81 (distinguishing "good cause"

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showing for sealing documents produced in discovery from "compelling reasons"
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standard when merits-related documents are part of court record). Accordingly, the

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terms of this protective order do not extend beyond the commencement of the trial.

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4 ~ 5.

DESIGNATING PROTECTED MATERIAL

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5.1

Exercise of Restraint and Care in Desi natin~Material for Protection.

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Each Party or Non-Party that designates information or items for protection under

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this Order must take care to limit any such designation to specific material that

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qualifies under the appropriate standards. The Designating Party must designate for

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protection only those parts of material, documents, items or oral or written

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communications that qualify so that other portions of the material, documents, items

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or communications for which protection is not warranted are not swept unjustifiably

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within the ambit of this Order.

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Mass, indiscriminate or routinized designations are prohibited. Designations

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that are shown to be clearly unjustified or that have been made for an improper

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purpose (e.g., to unnecessarily encumber the case development process or to impose

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unnecessary expenses and burdens on other parties) may expose the Designating

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Party to sanctions.

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

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designated for protection do not qualify for protection, that Designating Party must

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promptly notify all other Parties that it is withdrawing the inapplicable.designation.

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5.2

Manner and Timing of Desi ngations. Except as otherwise provided in

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this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

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stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

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under this Order must be clearly so designated before the material is disclosed or

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produced.

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Designation in conformity with this Order requires:
( for information in documentary form (e.g., paper or electronic
a)
documents, but excluding transcripts of depositions or other pretrial or trial
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proceedings), that the Producing Party affix at a minimum, the legend

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"
CONFIDENTIAL" or"HIGHLY CONFIDENTIAL — AEO",as may be

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appropriate,(hereinafter "CONFIDENTIAL legend"), to each page that contains

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protected material. If only a portion of the material on a page qualifies for

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protection, the Producing Party also must clearly identify the protected portions)

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(
e.g., by making appropriate markings in the margins).

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

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need not designate them for protection until after the inspecting Party has indicated

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which documents it would like copied and produced. During the inspection and

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before the designation, all of the material made available for inspection shall be

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deemed "CONFIDENTIAL." After the inspecting Party has identified the

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documents it wants copied and produced, the Producing Party must determine which

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documents, or portions thereof, qualify for protection under this Order. Then,

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before producing the specified documents, the Producing Party must affix the

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CONFIDENTIAL legend" to each page that contains Protected Material. If only a
"

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portion of the material on a page qualifies for protection, the Producing Party also

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must clearly identify the protected portions)(e.g., by making appropriate markings

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in the margins).

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( for testimony given in depositions that the Designating Party identifies
b)

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the Disclosure or Discovery Material on the record, before the close of the

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deposition all protected testimony.

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( for information produced in some form other than documentary and
c)

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f any other tangible items, that the Producing Party affix in a prominent place on
or

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2

the exterior of the container or containers in which the information is stored the

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legend "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL — AEO" as may be

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appropriate. If only a portion or portions of the information warrants protection, the

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Producing Party, to the extent practicable, shall identify the protected portion(s).

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Inadvertent Failures to Desi~ate. If timely corrected, an inadvertent
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failure to designate qualified information or items does not, standing alone, waive

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the Designating Party's right to secure protection under this Order for such material.

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

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efforts to assure that the material is treated in accordance with the provisions of this

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Order.

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CHALLENGING CONFIDENTIALITY DESIGNATIONS

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6.1

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designation of confidentiality at any time that is consistent with the Court's
Scheduling Order.

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Timing of Challen~. Any Party or Non-Party may challenge a

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.2

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq.

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.3

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

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the Designating Party. Frivolous challenges, and those made for an improper

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purpose (e.g., to harass or impose unnecessary expenses and burdens on other

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parties) may expose the Challenging Party to sanctions. Unless the Designating

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Party has waived or withdrawn the confidentiality designation, all parties shall

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continue to afford the material in question the level of protection to which it is

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entitled under the Producing Party's designation until the Court rules on the

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challenge.

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ACCESS TO AND USE OF PROTECTED MATERIAL

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7.1

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

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disclosed or produced by another Party or by a Non-Party in connection with this

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Action only for prosecuting, defending or attempting to settle this Action. Such

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Protected Material may be disclosed only to the categories of persons and under the

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conditions described in this Order. When the Action has been terminated, a

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Receiving Party must comply with the provisions of section 13 below(FINAL
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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

~I authorized under this Order.
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Disclosure of"CONFIDENTIAL"Information or Items. Unless

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otherwise ordered by the court or permitted in writing by the Designating Party, a

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Receiving Party may disclose any information or item designated

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CONFIDENTIAL" only to:
"

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( the Receiving Party's Outside Counsel of Record in this Action, as
a)

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well as employees of said Outside Counsel of Record to whom it is reasonably

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necessary to disclose the information for this Action;

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

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

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

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disclosure is reasonably necessary for this Action and who have signed the
Acknowledgment and Agreement to Be Bound"(Exhibit A);
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( the court and its personnel;
d)

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( court reporters and their staff;
e)

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( professional jury or trial consultants, mock jurors, and Professional
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Vendors to whom disclosure is reasonably necessary for this Action and who have

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signed the "Acknowledgment and Agreement to Be Bound"(Exhibit A);

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( the author or recipient of a document containing the information or a
g)
custodian or other person who otherwise possessed or knew the information;

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( during their depositions, witnesses, and attorneys for witnesses, in the
h)

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Action to whom disclosure is reasonably necessary provided:(1)the deposing party

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requests that the witness sign the form attached as E~iibit 1 hereto; and (2)they will

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not be permitted to keep any confidential information unless they sign the

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Acknowledgment and Agreement to Be Bound"(Exhibit A), unless otherwise
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agreed by the Designating Party or ordered by the court. Pages of transcribed

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deposition testimony or exhibits to depositions that reveal Protected Material may

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be separately bound by the court reporter and may not be disclosed to anyone except

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as permitted under this Stipulated Protective Order; and
( any mediator or settlement officer, and their supporting personnel,
i)

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

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7.3

Disclosure of"HIGHLY CONFIDENTIAL - AEO"Information or

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Items. Unless otherwise ordered by the court or permitted in writing by the

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Designating Party, a Receiving Party may disclose any information or item

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designated "HIGHLY CONFIDENTIAL - AEO" only to: those persons identified

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above in Section 7.2(a) and (c)-(i). "HIGHLY CONFIDENTIAL — AEO"

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information may not be disclosed to the officers, directors, and employees of the

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Receiving Party, but maybe disclosed to House Counsel for the Receiving Party.

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The parties agree that the parties may be provided by their counsel a summary

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document, or oral summary, setting forth the alleged infringers' full identities,

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revenues, and gross profits totals, as well as the plaintiff's sales, revenues and

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profits and from the sale of product affixed with the allegedly infringed designs) at

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issue in this Action, notwithstanding any party's designation of documents showing

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such information as"HIGHLY CONFIDENTIAL — AEO." It shall not be a

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violation of this protective order for Plaintiff to use such information to name

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revealed alleged infringers as defendants in this lawsuit or in a future lawsuit.

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8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

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IN OTHER LITIGATION

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

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that compels disclosure of any information or items designated in this Action as

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CONFIDENTIAL," that Party must:
"

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( promptly notify in writing the Designating Party. Such notification
a)
shall include a copy of the subpoena or court order;
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(b) promptly notify in writing the party who caused the subpoena or order

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to issue in the other litigation that some or all of the material covered by the

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subpoena or order is subject to this Protective Order. Such notification shall include

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a copy of this Stipulated Protective Order; and
( cooperate with respect to all reasonable procedures sought to be
c)

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pursued by the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with

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8

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

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action as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL — AEO" before a

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determination by the court from which the subpoena or order issued, unless the

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Party has obtained the Designating Party's permission. The Designating Party shall

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bear the burden and expense of seeking protection in that court of its confidential

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material and nothing in these provisions should be construed as authorizing or

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encouraging a Receiving Party in this Action to disobey a lawful directive from

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another court.

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ANON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED 1N THIS LITIGATION
( The terms of this Order are applicable to information produced by a
a)

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Non-Party in this Action and designated as "CONFIDENTIAL" or "HIGHLY

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CONFIDENTIAL — AEO". Such information produced by Non-Parties in

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connection with this litigation is protected by the remedies and relief provided by

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this Order. Nothing in these provisions should be construed as prohibiting a Non-

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4

Party from seeking additional protections.

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

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produce allon-Party's confidential information in its possession, and the Party is

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subject to an agreement with the Non-Party not to produce the Non-Party's

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confidential information, then the Party shall:
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age 13 of 16 Page I D

1)
( promptly notify in writing the Requesting Party and the Non-Party

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2

that some or all of the information requested is subject to a confidentiality

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agreement with allon-Party;
2)
( promptly provide the Non-Party with a copy of the Stipulated

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5

Protective Order in this Action, the relevant discovery request(s), and a reasonably

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specific description of the information requested; and
3)
( make the information requested available for inspection by the

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Non-Party, if requested.

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9

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

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14 days of receiving the notice and accompanying information, the Receiving Party

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may produce the Non-Party's confidential information responsive to the discovery

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request. If the Non-Party timely seeks a protective order, the Receiving Party shall

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not produce any information in its possession or control that is subject to the

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confidentiality agreement with the Non-Party before a determination by the court.

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Absent a court order to the contrary, the Non-Party shall bear the burden and

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expense of seeking protection in this court of its Protected Material.

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

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Protected Material to any person or in any circumstance not authorized under this

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Stipulated Protective Order, the Receiving Party must immediately(a) notify in

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writing the Designating Party of the unauthorized disclosures,(b)use its best efforts

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to retrieve all unauthorized copies of the Protected Material,(c) inform the person or

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persons to whom unauthorized disclosures were made of all the terms of this Order,

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and(d)request such person or persons to execute the "Acknowledgment and

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Agreement to Be Bound" that is attached hereto as Exhibit A.

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INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

1
2

inadvertently produced material is subject to a claim of privilege or other protection,

3

the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

4

Procedure 26(b)(5)(B). This provision is not intended to modify whatever

5

procedure may be established in an e-discovery order that provides for production

6 'I without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
7 ( insofar as the parties reach an agreement on the effect of disclosure of a
e),
8

communication or information covered by the attorney-client privilege or work

9

product protection, the parties may incorporate their agreement in the stipulated

10

protective order submitted to the court.

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12 ~ 12.

MISCELLANEOUS

13

12.1 Right to Further Relie£ Nothing in this Order abridges the right of any

14

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

15
16

Protective Order, no Party waives any right it otherwise would have to object to

17

disclosing or producing any information or item on any ground not addressed in this

18

Stipulated Protective Order. Similarly, no Party waives any right to object on any

19

ground to use in evidence of any of the material covered by this Protective Order.

2
0

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

21

Protected Material must comply with Local Civil Rule 79-5. Protected Material

2
2

may only be filed under seal pursuant to a court order authorizing the sealing of the

23

specific Protected Material at issue. If a Party's request to file Protected Material

2
4

under seal is denied by the court, then the Receiving Party may file the information

25

in the public record unless otherwise instructed by the court.

2
6
27 ~ 13.

FINAL DISPOSITION

28

After the final disposition of this Action, as defined in paragraph 4, within 60
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CasE~I2:16-cv-04689-RGK

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'age 15 of 16 Page ID

1

days of a written request by the Designating Party, each Receiving Party must return

2

all Protected Material to the Producing Party or destroy such material. As used in

3

this subdivision,"all Protected Material" includes all copies, abstracts, compilations,

4

summaries, and any other format reproducing or capturing any of the Protected

5

Material. Whether the Protected Material is returned or destroyed, the Receiving

6

Party must submit a written certification to the Producing Party (and, if not the same

7

person or entity, to the Designating Party) by the 60 day deadline that(1)identifies

8

( category, where appropriate) all the Protected Material that was returned or
by

9

destroyed and(2) affirms that the Receiving Party has not retained any copies,

10

abstracts, compilations, summaries or any other format reproducing or capturing any

11

of the Protected Material. Notwithstanding this provision, Counsel are entitled to

12

retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

13

transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

14

reports, attorney work product, and consultant and expert work product, even if such

15

materials contain Protected Material. Any such archival copies that contain or

16

constitute Protected Material remain subject to this Protective Order as set forth in

17

Section 4(DURATION).

18
19 ~ 14.

VIOLATION

2
0

Any violation of this Order may be punished by appropriate measures

21

including, without limitation, contempt proceedings andlor monetary sanctions.

2
2
23
4
2

FOR GOOD CAUSE SHOWN,IT IS SO ORDERED.
DATED: 2- I$ I Z~ ~~

25
2
6
27
28

G~
I
Hon. Alicia G. Rosen erg
United States Magistrate Judge
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'age 16 of 16 Page ID

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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4

[print or type full name], of

I
,

5

[
print or type full address], declare under penalty of perjury

6

that I have read in its entirety and understand the Stipulated Protective Order that

7

was issued by the United States District Court for the Central District of California

8

on [date] in the case ofZelouf West Ltd. v. Shoreline Wear, Inc., et al., Case No.

9

2
:16-cv-04689-RGK(AGR3c). I agree to comply with and to be bound by all the

10

terms of this Stipulated Protective Order and I understand and acknowledge that

11

f
ailure to so comply could expose me to sanctions and punishment in the nature of

12

contempt. I solemnly promise that I will not disclose in any manner any

13

information or item that is subject to this Stipulated Protective Order to any person

14

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 for the

16

Central District of California for enforcing the terms of this Stipulated Protective

17

Order, even if such enforcement proceedings occur after termination of this action.

18

I hereby appoint

[print or type full name] of
[print or type full address and

19
2
0

telephone number] as my California agent for service of process in connection with

21

this action or any proceedings related to enforcement of this Stipulated Protective

2
2

Order.

23

Date:

4
2

City and State where sworn and signed:

25
2
6

Printed name:

27
28

Signature:
-i6[PROPOSED]ORDER GRANTING STIPULATED PROTECTIVE ORDER