IV Solutions, Inc. v. Cobham Management Services, Inc.
Filing
43
STIPULATED PROTECTIVE ORDER by Magistrate Judge Patrick J. Walsh. re Stipulation for Protective Order 42 . (sbou)
1
2
3
4
5
6
7
8
9
10
11
12
13
UNITED STATES DISTRICT COURT
14
CENTRAL DISTRICT OF CALIFORNIA
15
WESTERN DIVISION
16
17
18
IV SOLUTIONS, INC., a California
corporation,
Plaintiff,
19
20
21
22
23
v.
COBHAM MANAGEMENT
SERVICES, INC., a Delaware
corporation,
Case No. 2:16-cv-06462 FMO (PJWx)
Honorable Fernando M. Olguin
STIPULATED PROTECTIVE
ORDER
Complaint Served:
Trial Date:
Sept. 19, 2016
March 13, 2018
Defendant.
24
25
26
27
28
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
1.
INTRODUCTION
2
1.1
3
Discovery in this action is likely to involve production of confidential,
PURPOSES AND LIMITATIONS
4
proprietary, or private information for which special protection from public
5
disclosure and from use for any purpose other than prosecuting this litigation may
6
be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
7
enter the following Stipulated Protective Order. The parties acknowledge that this
8
Order does not confer blanket protections on all disclosures or responses to
9
discovery and that the protection it affords from public disclosure and use extends
10
only to the limited information or items that are entitled to confidential treatment
11
under the applicable legal principles. The parties further acknowledge, as set forth
12
in Section 12.3, below, that this Stipulated Protective Order does not entitle them to
13
file confidential information under seal; Civil Local Rule 79-5 sets forth the
14
procedures that must be followed and the standards that will be applied when a
15
party seeks permission from the court to file material under seal.
16
1.2
GOOD CAUSE STATEMENT
17
This case involves allegations by Plaintiff IV Solutions, Inc. (“IVS”)
18
that defendant Cobham Management Services, Inc. (“Cobham”) failed to pay IVS
19
its full billed charges for medical services provided by IVS to Cobham’s member
20
“G.D.” (whose identity is protected herein from disclosure). Discovery in this case
21
will naturally contain information regarding G.D., G.D.’s medical condition, and
22
medical services provided by IVS to G.D., all of which is protected by the Health
23
Insurance Portability and Accountability Act (“HIPAA”). The parties must ensure
24
this information is kept confidential. Discovery in this case is also likely to seek
25
production of information regarding the parties’ trade secret, privileged, proprietary
26
or confidential information, including, without limitation, the sources of certain
27
drugs provided to G.D. for his treatment and the prices paid for such drugs.
28
///
-1-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
2
3
4
5
6
2.
DEFINITIONS
2.1
Action: IV Solutions, Inc. v. Cobham Management Services,
Inc., case number 2:16-cv-06462 FMO (PJWx).
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
7
(regardless of how it is generated, stored or maintained) or tangible things that
8
qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified
9
above in the Good Cause Statement.
10
2.4
“HIGHLY CONFIDENTIAL” Information or Items: any
11
Confidential information that any Party determines in good faith is particularly
12
sensitive, confidential, personal, and/or private, and/or the disclosure of which to
13
persons other than those set forth in Section 7.3 below is reasonably likely to cause
14
serious competitive harm or other harm.
15
16
17
2.5
Counsel: Outside Counsel of Record and House Counsel (as
well as their support staff).
2.6
Designating Party: a Party or Non-Party that designates
18
information or items that it produces in disclosures or in responses to discovery as
19
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.”
20
2.7
Disclosure or Discovery Material: all items or information,
21
regardless of the medium or manner in which it is generated, stored, or maintained
22
(including, among other things, testimony, transcripts, and tangible things), that are
23
produced or generated in disclosures or responses to discovery in this matter.
24
2.8
Expert: a person with specialized knowledge or experience in a
25
matter pertinent to the litigation who has been retained by a Party or its counsel to
26
serve as an expert witness or as a consultant in this Action.
27
28
2.9
House Counsel: attorneys who are employees of a party to this
Action. House Counsel does not include Outside Counsel of Record or any other
-2-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
outside counsel.
2
3
2.10 Non-Party: any natural person, partnership, corporation,
association, or other legal entity not named as a Party to this action.
4
2.11 Outside Counsel of Record: attorneys who are not employees of
5
a party to this Action but are retained to represent or advise a party to this Action
6
and have appeared in this Action on behalf of that party or are affiliated with a law
7
firm which has appeared on behalf of that party, and includes support staff.
8
9
10
2.12 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).
11
12
2.13 Producing Party: a Party or Non-Party that produces Disclosure
or Discovery Material in this Action.
13
2.14 Professional Vendors: persons or entities that provide litigation
14
support services (e.g., photocopying, videotaping, translating, preparing exhibits or
15
demonstrations, and organizing, storing, or retrieving data in any form or medium)
16
and their employees and subcontractors.
17
18
2.15 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.”
19
2.16 Receiving Party: a Party that receives Disclosure or Discovery
20
Material from a Producing Party.
21
3.
SCOPE
22
The protections conferred by this Stipulation and Order cover not only
23
Protected Material (as defined above), but also (1) any information copied or
24
extracted from Protected Material; (2) all copies, excerpts, summaries, or
25
compilations of Protected Material; and (3) any testimony, conversations, or
26
presentations by Parties or their Counsel that might reveal Protected Material.
27
28
Any use of Protected Material at trial will be governed by the orders of the
trial judge. This Order does not govern the use of Protected Material at trial.
-3-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
4.
2
DURATION
Even after final disposition of this litigation, the confidentiality obligations
3
imposed by this Order will remain in effect until a Designating Party agrees
4
otherwise in writing or a court order otherwise directs. Final disposition will be
5
deemed to be the later of (1) dismissal of all claims and defenses in this Action,
6
with or without prejudice; and (2) final judgment herein after the completion and
7
exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
8
including the time limits for filing any motions or applications for extension of time
9
pursuant to applicable law.
10
11
5.
DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection.
12
Each Party or Non-Party that designates information or items for protection under
13
this Order must take care to limit any such designation to specific material that
14
qualifies under the appropriate standards. The Designating Party must designate for
15
protection only those parts of material, documents, items, or oral or written
16
communications that qualify so that other portions of the material, documents,
17
items, or communications for which protection is not warranted are not swept
18
unjustifiably within the ambit of this Order.
19
Mass, indiscriminate, or routinized designations are prohibited. Designations
20
that are shown to be clearly unjustified or that have been made for an improper
21
purpose (e.g., to unnecessarily encumber the case development process or to
22
impose unnecessary expenses and burdens on other parties) may expose the
23
Designating Party to sanctions.
24
If it comes to a Designating Party’s attention that information or items that it
25
designated for protection do not qualify for protection, that Designating Party must
26
promptly notify all other Parties that it is withdrawing the inapplicable designation.
27
28
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
-4-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
2
under this Order must be clearly so designated before the material is disclosed or
3
produced.
4
5
Designation in conformity with this Order requires:
(a)
for information in documentary form (e.g., paper or electronic
6
documents, but excluding transcripts of depositions or other pretrial or trial
7
proceedings), that the Producing Party affix at a minimum, the legend
8
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) or “HIGHLY
9
CONFIDENTIAL” (hereinafter “HIGHLY CONFIDENTIAL” legend), to each
10
page that contains protected material. If only a portion or portions of the material on
11
a page qualifies for protection, the Producing Party also must clearly identify the
12
protected portion(s) (e.g., by making appropriate markings in the margins).
13
A Party or Non-Party that makes original documents available for inspection
14
need not designate them for protection until after the inspecting Party has indicated
15
which documents it would like copied and produced. During the inspection and
16
before the designation, all of the material made available for inspection will be
17
deemed “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL,” as appropriate.
18
After the inspecting Party has identified the documents it wants copied and
19
produced, the Producing Party must determine which documents, or portions
20
thereof, qualify for protection under this Order. Then, before producing the
21
specified documents, the Producing Party must affix the “CONFIDENTIAL” or
22
“HIGHLY CONFIDENTIAL” legend to each page that contains Protected
23
Material. If only a portion or portions of the material on a page qualifies for
24
protection, the Producing Party also must clearly identify the protected portion(s)
25
(e.g., by making appropriate markings in the margins).
26
(b)
for testimony given in depositions that the Designating Party identify
27
the Disclosure or Discovery Material on the record, before the close of the
28
deposition all protected testimony.
-5-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
(c)
for information produced in some form other than documentary and
2
for any other tangible items, that the Producing Party affix in a prominent place on
3
the exterior of the container or containers in which the information is stored the
4
legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” If only a portion or
5
portions of the information warrants protection, the Producing Party, to the extent
6
practicable, will identify the protected portion(s).
7
5.3
Inadvertent Failures to Designate. If timely corrected, an
8
inadvertent failure to designate qualified information or items does not, standing
9
alone, waive the Designating Party’s right to secure protection under this Order for
10
such material. Upon timely correction of a designation, the Receiving Party must
11
make reasonable efforts to assure that the material is treated in accordance with the
12
provisions of this Order.
13
6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
14
6.1
Timing of Challenges. Any Party or Non-Party may challenge a
15
designation of confidentiality at any time that is consistent with the Court’s
16
Scheduling Order.
17
6.2
Meet and Confer. The Challenging Party will initiate the dispute
18
resolution process (and, if necessary, file a discovery motion) under Local Rule
19
37.1 et seq.
20
6.3
The burden of persuasion in any such challenge proceeding will
21
be on the Designating Party. Frivolous challenges, and those made for an improper
22
purpose (e.g., to harass or impose unnecessary expenses and burdens on other
23
parties) may expose the Challenging Party to sanctions. Unless the Designating
24
Party has waived or withdrawn the confidentiality designation, all parties will
25
continue to afford the material in question the level of protection to which it is
26
entitled under the Producing Party’s designation until the Court rules on the
27
challenge.
28
///
-6-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
2
7.
ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is
3
disclosed or produced by another Party or by a Non-Party in connection with this
4
Action only for prosecuting, defending, or attempting to settle this Action. Such
5
Protected Material may be disclosed only to the categories of persons and under the
6
conditions described in this Order. When the Action has been terminated, a
7
Receiving Party must comply with the provisions of section 13 below (FINAL
8
DISPOSITION).
9
Protected Material must be stored and maintained by a Receiving Party at a
10
location and in a secure manner that ensures that access is limited to the persons
11
authorized under this Order.
12
7.2
Disclosure of “CONFIDENTIAL” Information or Items. Unless
13
otherwise ordered by the court or permitted in writing by the Designating Party, a
14
Receiving Party may disclose any information or item designated
15
“CONFIDENTIAL” only to:
16
(a)
the Receiving Party’s Outside Counsel of Record in this Action, as
17
well as employees of said Outside Counsel of Record to whom it is reasonably
18
necessary to disclose the information for this Action;
19
20
21
(b)
the officers, directors, and employees (including House Counsel) of
the Receiving Party to whom disclosure is reasonably necessary for this Action;
(c)
Experts (as defined in this Order) of the Receiving Party to whom
22
disclosure is reasonably necessary for this Action and who have signed the
23
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
24
(d)
the Court and its personnel;
25
(e)
court reporters and their staff;
26
(f)
professional jury or trial consultants, mock jurors, and Professional
27
Vendors to whom disclosure is reasonably necessary for this Action and who have
28
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
-7-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
2
3
(g)
the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;
(h)
during their depositions, witnesses, and attorneys for witnesses, in the
4
Action to whom disclosure is reasonably necessary provided: (1) the deposing party
5
requests that the witness sign the form attached as Exhibit A hereto; and (2) they
6
will not be permitted to keep any confidential information unless they sign the
7
“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
8
agreed by the Designating Party or ordered by the court. Pages of transcribed
9
deposition testimony or exhibits to depositions that reveal Protected Material may
10
be separately bound by the court reporter and may not be disclosed to anyone
11
except as permitted under this Stipulated Protective Order; and
12
13
14
(i)
any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by any of the parties engaged in settlement discussions.
7.3
Disclosure of “HIGHLY CONFIDENTIAL” Information or Items.
15
Unless otherwise ordered by the court or permitted in writing by the Designating
16
Party, a Receiving Party may disclose any information or item designated
17
“HIGHLY CONFIDENTIAL” only to:
18
(a)
the Receiving Party’s Outside Counsel of Record in this Action, as
19
well as employees of said Outside Counsel of Record to whom it is reasonably
20
necessary to disclose the information for this Action;
21
(b)
Experts (as defined in this Order) of the Receiving Party to whom
22
disclosure is reasonably necessary for this Action and who have signed the
23
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
24
(c)
the Court and its personnel;
25
(d)
court reporters and their staff;
26
(e)
professional jury or trial consultants, mock jurors, and Professional
27
Vendors to whom disclosure is reasonably necessary for this Action and who have
28
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
-8-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
2
(f)
the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;
3
(g)
during their depositions, witnesses, and attorneys for witnesses, in the
4
Action to whom disclosure is reasonably necessary provided: (1) the deposing party
5
requests that the witness sign the form attached as Exhibit A hereto; and (2) they
6
will not be permitted to keep any confidential information unless they sign the
7
“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
8
agreed by the Designating Party or ordered by the court. Pages of transcribed
9
deposition testimony or exhibits to depositions that reveal Protected Material may
10
be separately bound by the court reporter and may not be disclosed to anyone
11
except as permitted under this Stipulated Protective Order;
12
13
(h)
any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by any of the parties engaged in settlement discussions; AND
14
(i)
designated in-house counsel of the Receiving Party (including in-
15
house counsel’s support staff), provided that (1) the designated-in house counsel
16
has no involvement in competitive decision-making, (2) disclosure to the
17
designated in-house counsel is reasonably necessary for this litigation, (3) the
18
designated in-house counsel has signed the “Acknowledgement And Agreement To
19
Be Bound” (Exhibit A), and (4) the designated in-house counsel is a licensed
20
attorney admitted to practice law in at least one state of the United States or the
21
District of Columbia (or, in the case of in-house counsel’s support staff, that the
22
support staff is subject to the direct supervision of a licensed attorney, and the
23
licensed attorney is not Outside Counsel of Record).
24
8.
25
IN OTHER LITIGATION
26
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
If a Party is served with a subpoena or a court order issued in other litigation
27
that compels disclosure of any information or items designated in this Action as
28
“CONFIDENTIAL,” or “HIGHLY CONFIDENTIAL” that Party must:
-9-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
2
(a)
promptly notify in writing the Designating Party. Such notification
will include a copy of the subpoena or court order;
3
(b)
promptly notify in writing the party who caused the subpoena or order
4
to issue in the other litigation that some or all of the material covered by the
5
subpoena or order is subject to this Protective Order. Such notification will include
6
a copy of this Stipulated Protective Order; and
7
8
(c)
cooperate with respect to all reasonable procedures sought to be
pursued by the Designating Party whose Protected Material may be affected.
9
If the Designating Party timely seeks a protective order, the Party served with
10
the subpoena or court order will not produce any information designated in this
11
action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” before a
12
determination by the court from which the subpoena or order issued, unless the
13
Party has obtained the Designating Party’s permission. The Designating Party will
14
bear the burden and expense of seeking protection in that court of its confidential
15
material and nothing in these provisions should be construed as authorizing or
16
encouraging a Receiving Party in this Action to disobey a lawful directive from
17
another court.
18
9.
19
PRODUCED IN THIS LITIGATION
20
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
(a)
The terms of this Order are applicable to information produced by a
21
Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
22
CONFIDENTIAL.” Such information produced by Non-Parties in connection with
23
this litigation is protected by the remedies and relief provided by this Order.
24
Nothing in these provisions should be construed as prohibiting a Non-Party from
25
seeking additional protections.
26
(b)
In the event that a Party is required, by a valid discovery request, to
27
produce a Non-Party’s confidential information in its possession, and the Party is
28
subject to an agreement with the Non-Party not to produce the Non-Party’s
-10-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
confidential information, then the Party will:
2
(1)
promptly notify in writing the Requesting Party and the Non-
3
Party that some or all of the information requested is subject to a confidentiality
4
agreement with a Non-Party;
5
(2)
promptly provide the Non-Party with a copy of the Stipulated
6
Protective Order in this Action, the relevant discovery request(s), and a reasonably
7
specific description of the information requested; and
8
9
(3)
make the information requested available for inspection by the
Non-Party, if requested.
10
(c)
If the Non-Party fails to seek a protective order from this court within
11
14 days of receiving the notice and accompanying information, the Receiving Party
12
may produce the Non-Party’s confidential information responsive to the discovery
13
request. If the Non-Party timely seeks a protective order, the Receiving Party will
14
not produce any information in its possession or control that is subject to the
15
confidentiality agreement with the Non-Party before a determination by the court.
16
Absent a court order to the contrary, the Non-Party will bear the burden and
17
expense of seeking protection in this court of its Protected Material.
18
10.
19
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
20
Protected Material to any person or in any circumstance not authorized under this
21
Stipulated Protective Order, the Receiving Party must immediately (a) notify in
22
writing the Designating Party of the unauthorized disclosures, (b) use its best
23
efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
24
person or persons to whom unauthorized disclosures were made of all the terms of
25
this Order, and (d) request such person or persons to execute the “Acknowledgment
26
and Agreement to Be Bound” that is attached hereto as Exhibit A.
27
///
28
///
-11-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
11.
2
PROTECTED MATERIAL
3
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
(a)
When a Producing Party gives notice to Receiving Parties that certain
4
inadvertently produced material is subject to a claim of privilege or other
5
protection, the obligations of the Receiving Parties are those set forth in Federal
6
Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
7
whatever procedure may be established in an e-discovery order that provides for
8
production without prior privilege review.
9
12.
10
11
MISCELLANEOUS
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
12.2 Right to Assert Other Objections. By stipulating to the entry of this
13
Protective Order no Party waives any right it otherwise would have to object to
14
disclosing or producing any information or item on any ground not addressed in
15
this Stipulated Protective Order. Similarly, no Party waives any right to object on
16
any ground to use in evidence of any of the material covered by this Protective
17
Order.
18
12.3 Filing Protected Material. A Party that seeks to file under seal any
19
Protected Material must comply with Civil Local Rule 79-5. Protected Material
20
may only be filed under seal pursuant to a court order authorizing the sealing of the
21
specific Protected Material at issue. If a Party's request to file Protected Material
22
under seal is denied by the court, then the Receiving Party may file the information
23
in the public record unless otherwise instructed by the court.
24
13.
25
FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4, within 60
26
days of a written request by the Designating Party, each Receiving Party must
27
return all Protected Material to the Producing Party or destroy such material. As
28
used in this subdivision, “all Protected Material” includes all copies, abstracts,
-12-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
compilations, summaries, and any other format reproducing or capturing any of the
2
Protected Material. Whether the Protected Material is returned or destroyed, the
3
Receiving Party must submit a written certification to the Producing Party (and, if
4
not the same person or entity, to the Designating Party) by the 60 day deadline that
5
(1) identifies (by category, where appropriate) all the Protected Material that was
6
returned or destroyed and (2) affirms that the Receiving Party has not retained any
7
copies, abstracts, compilations, summaries or any other format reproducing or
8
capturing any of the Protected Material. Notwithstanding this provision, Counsel
9
are entitled to retain an archival copy of all pleadings, motion papers, trial,
10
deposition, and hearing transcripts, legal memoranda, correspondence, deposition
11
and trial exhibits, expert reports, attorney work product, and consultant and expert
12
work product, even if such materials contain Protected Material. Any such archival
13
copies that contain or constitute Protected Material remain subject to this Protective
14
Order as set forth in Section 4 (DURATION).
15
///
16
///
17
///
18
///
19
///
20
///
21
///
22
///
23
///
24
///
25
///
26
///
27
///
28
///
-13-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
2
14.
WILLFUL VIOLATIONS
Any willful violation of this Order may be punished by civil or criminal
3
contempt proceedings, financial or evidentiary sanctions, reference to disciplinary
4
authorities, or other appropriate action at the discretion of the Court.
5
6
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8
DATED: July 28, 2017
WOLF, RIFKIN, SHAPIRO, SCHULMAN &
RABKIN, LLP
9
10
By
11
12
/s/ Eric Levinard
Marc E. Rohatiner
Eric Levinard
Attorneys for Plaintiff IV Solutions, Inc.
13
14
DATED: July 28, 2017
CROWELL & MORING LLP
15
By
16
17
18
19
/s/ Andrew Holmer
Jennifer S. Romano
Daniel M. Glassman
Andrew Holmer
Attorneys for Defendant Cobham
Management Services, Inc.
20
21
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
22
23
24
DATED: July 31, 2017
________________________________
HON. PATRICK J. WALSH
United States Magistrate Judge
25
26
27
28
-14-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
EXHIBIT A
2
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4
I, _____________________________ [full name], of _________________
5
[full address], declare under penalty of perjury that I have read in its entirety and
6
understand the Stipulated Protective Order that was issued by the United States
7
District Court for the Central District of California on [_____] in the case of IV
8
Solutions, Inc. v. Cobham Management Services, Inc., case number 2:16-cv-06462
9
FMO (PJWx). I agree to comply with and to be bound by all the terms of this
10
Stipulated Protective Order and I understand and acknowledge that failure to so
11
comply could expose me to sanctions and punishment in the nature of contempt. I
12
solemnly promise that I will not disclose in any manner any information or item
13
that is subject to this Stipulated Protective Order to any person or entity except in
14
strict compliance with the provisions of this Order.
15
I further agree to submit to the jurisdiction of the United States District Court
16
for the Central District of California for the purpose of enforcing the terms of this
17
Stipulated Protective Order, even if such enforcement proceedings occur after
18
termination of this action. I hereby appoint __________________________ [full
19
name] of _______________________________________ [full address and
20
telephone number] as my California agent for service of process in connection
21
with this action or any proceedings related to enforcement of this Stipulated
22
Protective Order.
23
Date: ______________________________________
24
City and State where signed: _________________________________
25
26
Printed name: _______________________________
27
28
Signature: __________________________________
-15-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
1
CERTIFICATION
2
I, ANDREW HOLMER, am an attorney in the law firm of Crowell &
3
Moring LLP, counsel of record for Defendant Cobham Management Services, Inc.
4
Under C.D. Cal. Local Rule 5-4.3.4(a)(2)(i), I hereby attest that all other
5
signatories on whose behalf this filing is submitted concur in the filing’s content
6
and have authorized the filing.
7
8
Dated:
July 28, 2017
CROWELL & MORING LLP
9
/s/
Andrew Holmer
Jennifer S. Romano
Daniel M. Glassman
Andrew Holmer
10
11
12
Attorneys for Defendant
Cobham Management Services, Inc.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-16-
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-06462 FMO (PJWX)
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?