Nichelle Gooden v. Total Safety U.S., Inc. et al

Filing 18

STIPULATED PROTECTIVE ORDER by Magistrate Judge Alicia G. Rosenberg. re Stipulation for Protective Order 17 . NOTE CHANGES MADE BY THE COURT. (See Order for Further Details) (kl)

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Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 1 of 14 Page ID #:210 u 1 2 ' 3 4 JOSEPH A. SCHWACHTER,Bar No.10812 ischwachter( kcha man(c~littler.comkcha LIT~EI~MENDELS~N,P.C. 333 Bush Street 34th Floor San Francisco, ~A 94104 Telephone:(415)433-1940 Facsunile:(415)399-8490 Ea~~,.~ ,r* r 5 6 Attorneys for Defendant TOTAL SAFETY U.S.,INC. ~~ ~':~ ~~f ~ ~~~ ~ Q, ~., fF~ ~~„ 7 8 9 .~ l0 ~. 11 ° i d' SCOTT CUMIVIINGS LEE FR.ANCK lee cummin .C. F 1025 W 190 St. Suite 200 Gardena, CA 90248 Phone: 310 295-2195 ( Facsimi e: 10)295-2180 ' M :~~~ ~~ ~ £~•~ ~. A ! ~'~ is ~~' ~r~ ~, 12 13 ig~ Attorneys for Plaintiff N iCHELLE GOODEN a rm 14 iJNITED STATES DISTRICT COURT IS CENTRAL DISTRICT OF CALIFORrIIA 16 17 IVICHELLE GOODEN, 18 19 2 0 21 ?2 2 3 Plaintiff, CASE NO. 2:16-CV-05620-VAP-AGR ASSIGNED TO HON. VIRGII~]IA A. PHILLIPS vs. TOTAL SAFETY U.S.,INC. LEROY JOHNSON,and DOSS 1 to 100,inclusive, Defendants. STIPIULATEI~ PROTECTIVE OI~IDEyt Date: Time: Dept.: Judge: 2 4 25 2 6 2 7 28 lLEit AIENDFLSWl.P.C. X13BuN5Voet 34tl~ Floc W Frand~,G 911W 415. 1.19/0 p 5 Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 2 of 14 Page ID #:211 1 ' 2 3 4 5 6 7 8 9 10 P~JRPOSES AND LIlVIITATIONS Disclosure and discovery activity in this action are likely to involve 1. 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. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or items th~.t are entitled to confidential treatment under the applicable legal prianciples. The parties further acknowledge, as set 12 orth in Section 12.3, below,that this Stipulated Protective Order does not entitle them f to file confidential information under seal; Civil Local Rule 79-5 sets forth the 13 procedures that must be followed and the standards that will be applied when a party 14 seeks permission from the count to file material under seal. li 15 . 2 DEFINI7CI()1VS 16 2 .1 Challenging.Party: a Party or Non-Party that challenges the 17 designation ofinformation or items under this Order. 18 "CONFIDENTIAY,"•Information.or Items:, information (regardless ofhow it is generated,stored or maintained)or tangible.things that qualify for protection under Federal Rule of Civil Procedure 26(c). 19 2 0 21 2 2 3 2 4 2 5 2 6 2 2 .2 2 .3 Counsel(without qualifier): Outside Counsel ofRecord and House Counsel(as well as their support staffl. 2 .4 . Designating Party: a~Party orNon-Party that designates information or items as "CONFIDENTIAL.',' 2 .5 Disclosure or .Discovery Material: all items or information, regardless of the medium or manner in which it' is generated, stored, or maintained 7 2 8 2 7lFRn1ENDEtSOtLP.C. 3319u~h SVao{ 40 3 Floc aii~:rdcoo.CA BAIOd : 41aAi1f930 [V~ ase o. Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 3 of 14 Page ID #:212 ,. . _ 1 2 .. (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in this matter. 2.6 3 Expert: ~ a person with specialized knowledge or experience in a 4 matter pertinent to the litigation who has been retained by a Party or its counsel to serve 5 as an expert witness or as a consultant in this action. 2.11 Producing Party: a Party or Non-Party that produces Disclosure or 6 7 Discovery Material in this action. 8 9 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing,storing, or retrieving data in any form or medium)and 11 • 2.12 Professional Vendors: persons or entities that provide litigation their employees and subcontractors. 12 2.13 Protected Material: any Disclosure or Discovery Material that is 13 designated as"CONFIDENTIAL" and that is produced by a party to this litigation or a 14 Non-Party that received the Disclosure or Discovery Material through anon-public or 15 unlawful manner. 2.14 Receiving Party: a Party that receives Disclosure or Discovery 16 17 Material from a Producing Party. 18 3. i9 The protections conferred by this Stipulation and Order cover not only 2 0 Protected Material(as defined above), but also(1)any information copied ox extracted 21 from Protected Material;(2)all copies, excerpts, or compilations ofProtected Material; 22 and (3) any testimony, or presentations by Parties or their Counsel that might reveal 23 Protected Material. However, the protections conferred by this Stipulation and Order 2 4 do not cover the following information:(a)any information that is in the public domain 25 at the time of disclosure to a Receiving Party or becomes part ofthe public domain after 2d its disclosure to a Receiving Party as a result ofpublication not involving a violation of 2 7 this Order, including becoming part ofthe public record through trial or otherwise; and 2 8 ~n~an,~rroasor~P.c. 17]BunSaat 3aA~Floor san Frandsco,CA 94106 ai5.ay.~eco ORDER SCOPE 2. ase o. -cv- - Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 4 of 14 Page ID #:213 (b)any information known to the Receiving Party prior to the disclosure or obtained by 2 the Receiving Party after the disclosure from a source who obtained the information 3 lawfully. Any- use of Protected Material at trial shall be governed by a separate 1 4 agreement or order. 5 4 . 6 Even after final disposition ofthis litigation,the confidentiality obligations 7 imposed by this Order shall remain in effect_until a Designating Party agrees otherwise 8 in writing or a court order otherwise directs. Final disposition shall be deemed to be the DURATIOI~ 9 ~' later of (1)dismissal of all claims and defenses in this action, with or without prejudice; 10 and (2) final judgment herein after the completion and exhaustion of all appeals, 11 rehearings,remands,trials, or reviews ofthis action, including the time limits for filing 12 any motions or applications for extension oftime pursuant to applicable law. 13 5 . DESIGNATING PltO'I'~CTEY)1VIATERTAT, 14 5.1 Exercise of Restraint and Care in Designating Material for 15 Protection. Each Party or Non-Party that designates information or items for protection 16 under this Order must take care to limit any such designation to specific material that 17 qualifies under the appropriate standards. The Designating Party must designate for 18 protection only those parts of material, documents, items, or oral or written 19 2 0 communications that qualify — so that other portions ofthe material, documents, items, or communications for which protection is not warranted are not swept unjustifiably 21 within the ambit ofthis Order. • 2 2 Mass, indiscriminate, or routinized designations are prohibited. 2 3 Designations that axe shown to be clearly unjustified or that have been made for an 2 4 improper purpose (e.g., to unnecessarily encumber or retard the case development 2 5 process or to impose unnecessary expenses and burdens on other parties) expose the 2 6 Designating Party to sanctions. 2 7 2 8 lIfRIAEPAEL50N.P.C. 3 au~nstr~~ v 3 Fbor 1N ten Fimidsm,CA 9ND1 415.41i.19C0 Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 5 of 14 Page ID #:214 1 Ifit comes to a Designating Party's attention that information or items that 2 it designated for protection do not qualify for protection,that Designating Party must 3 1 promptly notify all other Parties that it is withdrawing the mistaken designation. 5.2 4 Manner and Timing ofDesignations. Except as otherwise provided 5 in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 7 under this Order must be clearly so designated before the material is disclosed or 8 produced. 9 Designation in conformity with this Order requires: 10 ( for information in documentary form (e.g., paper or electronic a) 11 documents, but excluding transcripts of depositions or other pretrial or trial 12 proceedings), that the Producing Party affix the legend "CONFIDENTIAL" to each 13 page that contains protected material. If only a portion or portions ofthe material on a 14 page qualifies for protection, the Producing Party also must clearly identify the 15 protected portions)(e.g., by making appropriate markings in the margins). 16 17 or f inspection need not designate them for protection until after the inspecting Pa1-ty has 18 indicated which material it would like copied and produced. During the inspection and 19 • A Party or Non-Part;!that makes original documents or materials available before the designation, all ofthe material made available for inspection shall be deemed CONFYDENTIAL." After the inspecting Party has identified the documents it wants 20 " ?2 copied and produced,the Producing Party must deternune which documents,or portions thereof, qualify for protection under this Order. Then, before producing the specified 23 documents,the Producing Party must affix the"CONFIDENTIAL"legend to each page 2 4 that contains Protected Material. If only a.portion or portions ofthe material on a page 25 qualifies for protection, the Producing Party also must clearly identify the protected 2 6 ~ ~' portions)(e.g., by making appropriai:e the margins). 21 2 7 28 ~ MEt~DELSON,P.C. i xL7Bush 54ao1 3 Floe 11h 4nflantitto,CA 94101 -0tid13.f040 • ~ a ~ c;ase tvo. Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 6 of 14 Page ID #:215 ^ (b) for testimony given in deposition 1 ~uac~ae~that the Designating Party identify on the record, before the close ofthe 2 3 all protected testimony. deposition, 4 ( for information produced in some form other than documentary and c) 5 f any other tangible items,that the Producing Pariy affix in a prominent place on the or 6 exterior of the container or containers in which the information or item is stored the 7 ' legend "CONFIDENTIAL." If only a portion or portions of the information or item 8 warrant protection, the Producing Party, to the extent practicable, shall identify the 9 protected portion(s). 5.3 10 Tnad~ertent Failures, to Designate. If timely corrected (within 14 11 days of production), an inadvertent failure to designate qualified information or items 12 does not, standing alone, waive the Designating Party's right to secwre protection under 13 this Order for such material. Upon timely correction of a designation, the Receiving 14 Party must make reasonable efforts to assure that the material is treated in accordance 15 with the provisions ofthis Order. 5.4 16 Designation by Receiving Party. IfReceiving Party determines that 17 material produced by Producing Party includes Protected Material that was not obtained 18 by the Producing Party after the disclosure from a source who obtained the information 19 lawfully,then Receiving Party may designate those documents as confidential by giving 2 0 notice to Producing Party within thirty (30) days of production or thirty (30) days of 21 signing ofthis order, whichever is later. 2 2 2 3 C~ALLIEIiTGING CONFIDENT~AALIT'S~ I)ESIGNA'TIOI~TS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 2 4 designation ofconfidentiality at any time that is consistent with the Court's Scheduling 2 5 Order. 2 6 2 7 6 . 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37.1 et seq. 8 2 ILFR AIENDELS01l,P.C. S Bush Streel i3 30tl~ Floor pn Frawicm,CA 9J1W 615.43J.19i0 F ~ Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 7 of 14 Page ID #:216 6.3 1 2 The burden of persuasion in any such challenge proceeding shall be on the Designating Party.Frivolous challenges,and those made for an improper purpose 3 ( e.g., to harass or impose unnecessary expenses and burdens on other parties) may 4 expose the Challenging Party to sanctions. Unless the Designating Party has waived the 5 confidentiality designation by failing to file a motion to retain confidentiality as 6 described above, all parties shall continue to afford the material in question the level of 7 protection to which it is entitled under the Producing Party's designation until the court 8 rules on the challenge. 9 •~ 7 . ACCESS TO AND USE OF PROTECTED MA'TE~[AL to .1 7 Basic Principles. A Receiving Party may use Protected Material that 11 is disclosed or produced by another Party ox by allon-Party in connection with this case 12 only for prosecuting, defending, or attempting to settle this litigation. Such Protected 13 Material may be disclosed only to the categories of persons and under the conditions 14 described in this Order. When the litigation has been terminated,a Receiving Party must 15 comply with the provisions ofsection 13 below(FINAL DISPOSITIOI~. 16 Protected Material must be stored and maintained by a Receiving Party at 17 a location and in a secure mariner that ensures that access is limited to the persons 18 authorized under this Order. 19 .2 7 Disclosure of "CONFIDENTIAL" Information or Items. Unless 2 0 othei~uise ordered by the court or permitted in writing by the Designating Party, a 21 Receiving Party may disclose any information or item designated "CONFIDENTIAL" 2 2 only to: 2 3 (a) the Receiving Party's Outside Counsel ofRecord in this action, as well 2 4 as employees of said Outside Counsel ofRecord to whom it is reasonably necessary to 2 5 disclose the information for this litigation; 2 6 2 7 2 8 ' AIENOELSON,PL. RHi 2 8u~Sheel ii 7fIh Floor : Frandom.G 8t10! vi 4150.1319J0 ( the officers, directors, and employees (including House Counsel) of b) the Receiving Party to whom disclosure is reasonably necessary for this litigation; Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 8 of 14 Page ID #:217 1 (c) Experts (as defined in this Order) of the Receiving Party to whom 2 disclosure is. reasonably necessary for this litigation and who have signed the 3 Aclrnowledgment and Agreement to Be Bound"(Exhibit A); " 4 ( the court and its personnel; d) 5 ( court reporters and their staff, professional jury or trial consultants, e) 6 mock jurors, and Professional Vendors to whom disclosure is reasonably necessary for 7 this litigation and who have signed the"Acknowledgment and Agreementto Be Bound" Exhibit A); 8 ( 9 (~ during their depositions, witnesses in the action to whom disclosure is 10 reasonably necessary and who have signed the"Acknowledgment and Agreement to Be 11 Bound" (Exhibit A), unless otherwise agreed by the Designating Party or ordered by 12 13 the court. Pages of transcribed deposition testimony or exhibits to depositions that ~ marked by the court reporter and reveal Protected Material must be separately 14 may not be disclosed to anyone except as permitted under this Stipulated Protective 15 Order. 16 17 18 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise.possessed or knew the information. ( any mediator or settlement officer, and their supporting personnel, h) 19 mutually agreed upon by any ofthe parties engaged in settlement discussions. 2 0 PRO~'~CTED MA'B'ERl[~L ~TJ~POEN~D ~R OI2DER~I~ PRODUCED IN OT~R ]LYTIGATgOIV 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 21 2 2 2 3 2 4 2 5 2 6 2 7 2s ~tEaA+o+oasoe,P.c. ~a,r~so-oa~ 34mFtoor an flsKixo.G 9N64 Ati413.19~A ~ . as"CONFIDENTIAL," that Party must: ( promptly notify iri writing the Designating Pariy. Such notification a) shall include a copy ofthe subpoena or court order; ( promptly notify in writing the party who caused the subpoena or order b) to issue in the other litigation that some or all ofthe material covered by the subpoena Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 9 of 14 Page ID #:218 1 or order is subject to this Protective Order. Such notification shall include a copy o£this 2 Stipulated Protective Order; and 3 ( cooperate with respect to all reasonable procedures sought to be c) 4 5 pursued by the Designating Party whose Protected Material maybe affected. Ifthe Designating Party timely seeks a protective order within 14 days,the 6 Party served with the subpoena or court order shall not produce any information 7 designated in this action as "CONFIDENTIAL" before a determination by the court 8 from which the subpoena or order issued, unless the Party has obtained the Designating Pariy's permission. The Designating Party shall bear the burden and expense ofseeking 9 10 11 protection in that court of its confidential material —and nothing in these provisions should be construed as authorizing or encouraging a Receiving Party in this action to 12 disobey a lawful directive from another court. 13 14 15 16 17 18 19 2 0 21 2 2 23 2 4 25 2 6 2 7 9 . A I~tON-PAR~'~'S PROTECTED MATERIAIL SOUG~T'TO BE PI~OI)UC~I)IN THIS LITIGA~'IOl~T ( The terms of this Order are applicable to information produced by a a) Non-Party in this action and designated as "CONFIDENTIAL." Such information produced by Non-Parties in connection with this litigation is protected by the remedies and relief provided by this Order. Nothing in these provisions should be construed as prohibiting allon-Party from seeking additional protections. ( In the event that a Pariy is required, by a valid discovery request, to b) produce allon-Party's confidential information in its possession, and the Party is subject to an explicit agreement with the Non-Party not to produce the Non-Party's confidential information,then the Party shall: ( notify in writing the Requesting Party within 7 business days oftheir 1) request. Such notification shall include a copy of explicit agreement between the Producing Party and Non-Party and include written verification of the Non-Party's assent to the agreement; and notify the Non-Party that some or all of the information requested is subject to a confidentiality agreement; 2 s ~n~ u¢Noaso~L P.c. 3 778uch S4ea1 341h Floor an Farclxa.G141101 415./J3.1990 Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 10 of 14 Page ID . . #:219 (2) 1 promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this litigation, the relevant discovery request(s), and a reasonably 3 specific description of the information requested; and, (3) make the information requested available for inspection by the Non- 4 5 Party. 6 (c) If the Non-Party fails to object or seek a protective order from this 7 court within 14 days of receiving the notice and accompanying information, the 8 Receiving Party must produce the Non-Party's confidential information responsive to 9 the discovery request. If the Non-Party timely seeks a protective order, the Receiving 10 Party shall not produce any information in its possession or control that is subject to the 11 confidentiality agreement with the Non-Party before a determination by the court. I2 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 13 of seeking protection in this court of its Protected Material. 14 (d) The identities, locations, and contact information of any Non-Party 15 l ikely to have witnessed events likely to prove or disprove the allegations made in the ~16 Parties' complaints and answers shall not be Designated as Protected Material. 17 18 19 2 0 21 2 2 2 3 2 4 2 5 2 6 .27 2 8 ~a~oaso►tac. 33lBusfi 6trcel 31NFloor WFrandtm,G B{10/ A15.LTJ.1910 9.0. ~A~JTB[OR~ZED ~YSC~OSVRE O]E Pi20'~.']EC°I'~ID l YIC~'I'~RIAL I a Receiving Party learns that, by inadvertence or otherwise, it has f disclosed Protected Material to any person or in any circumstance not authorized under this Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the terms pf this Order, and (d) request such person or persons to execute the "Acknowledgment and Agreement to Be Bound" that is attached hereto as E~ibit A. Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 11 of 14 Page ID # :220 1 2 3 4 5 6 7 8 9 10 11. ~iA]DVERTENT PROI)UC'TI~IV O~ PRIVII~EGEgD OR 07C]~EI~WI~E PRO'~ECTED MA.TERIA.L When a Producing Party gives notice to Receiving Parties that certain inadvertently produced material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure may be established in an e-discovery order that provides for production without prior .privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a communication or i nformation covered by the attorney-client privilege or work product protection, the parties may incorporate their agreement in the stipulated protective order submitted to 11 the court. T2 13 14 15 16 17 18 19 ' 20 21 22 23 2 4 25 2 6 12. NdISCEL]LANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 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 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 ground to use in evidence of any of the material covered by this Protective Order. 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected Material must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to a court order authorizing the sealing of the specific Protected Material at issue. If a Receiving Parly's request to file Protected Material under seal pursuant to Civil Local Rule is denied by the court, then the Receiving Party may file the information in the public record unless otherwise instructed by the court. 2 7 28 ' ►1ENOFJ.SON, P.G 1LER 3J3 gush SVael 310 Floor tinRangaco, CA 9fI06 4tSlXilB4o o. Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 12 of 14 Page ID # :221 13. ~'~TAYl1)TSPOSITIOIV Within 60 days after the final disposition of this action, as defined in 2 4 paragraph 4, each Receiving Party must return all Protected Material to the Producing Party or destroy such material. As used in this subdivision, "all Protected Material" 5 includes all copies, abstracts, compilations, summaries, and any other format 6 reproducing or capturing any ofthe Protected Material. Whether the Protected Material 7 is returned or destroyed, the Receiving Party must submit a written certification to the 3 8 ' Producing Party (and, if not the same person or entity, to the Designating Party) by the 9 60 day deadline that affirms that the Receiving Party has not retained any copies, 10 11 the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 12 archival copy of all pleadings, motion papers, txial, deposition, and hearing transcripts, 13 legal memoranda,correspondence,deposition and trial exhibits, expert reports,attorney 14 work product, and consultant and expert work product, even if such materials contain 15 Protected Material. Any such archival copies that contain or constitute Protected 16 Material remain subject to this Protective Order as set forth in Section 4(DUR.ATIOI~. 17 • 18 ' • abstracts, compilations,summaries or any other format reproducing or capturing any of measures including, without limitation, contempt proceedings and/or monetary 19 sanctions. ao 14. Any violation ofthis Order may be punished by any and all appropriate IT IS SO STIPULATED,THROUGH COUNSEL OF RECORD. 21 2 2 ~~ ~~ ~i DATED:~ ,2017 ~ /~, ~~/,, J ~ c,. ,( hC 2 3 4 2 2 5 2 6 2 7 .. 28 iLERMEFIDE150N.P.C. ' 37 3 Bush SUeal 7NFloor 3 anflardSm,CA 9A100 415~33.19l0 LITTLER MENDELSON,P.C. Attorneys for Defendant TOTAL SAFETY U.S.,INC. Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 13 of 14 Page ID ' ~ #:222 1 DATED: January ~4 ,2017 2 EE STEVENS & MCMILLAN Attorneys for Plaintiff MICHELLE GOODEN 3 4' 5 ' 6 7 8 9 PURSUANT TO STIPULATION,IT IS SO ORDERED. 10 11 12 • ~ DATED: 3 2~ 2D I ~ 14 ~15 16 17 18 19 2 0 21 2 2 2 3 2 4 5 2 2 6 2 7 2 8 lLQt AIENURSON,P.G 3 BuSA 64aa1 V 34Uf Float tm frard~oo,CA 941W 415./33.1960 l~l.,(~I.CC.k, United States Distri 13 n agistrate J ge Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 14 of 14 Page ID # :223 1 11: 1 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 T, [print or type full name], of 4 [ print or type full address], declare under penalty ofperjury that I 5 have read in its entirety and understand the Stipulated Protective Order that was issued 6 by the United States District Court for the Northern District of California on [date] in ~ I the case of g l [insert formal name of the case and the number and initials assigned to it by the court]. I agree to comply with and to be bound by all the terms of 9 this Stipulated Protective Order and I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that is 1~ subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions ofthis Order. 14 X further agree to submit to the jurisdiction of the United States District 15 Court for the Central District of California for the purpose ofenforcing the terms ofthis 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination ofthis action. I hereby appoint 18 [print or type full name] [print or type full address and 19 of 2 0 telephone number] as my California agent for service ofprocess in connection with this 21 action or any proceedings related to enforcement ofthis Stipulated Protective Order. 22 Date: 23 City and State where sworn and signed: 2 4 Printed name: 25 Signature: 2 6 2 7 Firmwide:145274590.1 070157.1010 2 8 ILQi ' MQAF150N,P.C. 3 33Butli5trwl 3 Floor 4N an : Ftandaoo,CA B{706 415.43119J0

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