Construction Laborers Trust Funds for Southern California Administrative Company v. Morrow-Meadows Corporation et al

Filing 60

PROTECTIVE ORDER by Magistrate Judge Alka Sagar re Stipulation for Protective Order 57 . (See document for complete details) (afe)

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1 2 3 4 5 6 7 8 9 10 J. DAVID SACKMAN (SBN 106703) Email: REICH, ADELL & CVITAN, APC 3550 Wilshire Boulevard, Suite 2000 Los Angeles, California 90010-2421 Telephone: (213) 386-3860, Facsimile: (213) 386-5583 Attorneys for Plaintiff Construction Laborers Trust Funds for Southern California Administrative Co. DAVID S. MCLEOD (SBN 66808) Email: MCLEOD & WITHAM LLP 300 S. Grand Avenue, Suite 2525 Los Angeles, CA 90071 Telephone: (213) 627-3600; Facsimile: (213) 627-6290 Attorneys for Defendants Morrow-Meadows Corporation and American Contractors Indemnity Co. 11 12 13 14 15 16 J. PAUL MOORHEAD (SBN 240029) Email: LAQUER, URBAN, CLIFFORD & HODGE LLP 225 South Lake Avenue, Suite 200 Pasadena, California 91101-3030 Telephone: (626) 449-1882; Facsimile: (626) 449-1958 Attorneys for Intervenors - Defendants, Trustees of the Southern California IBEW-NECA Pension Plan, et al. 17 18 19 UNITED STATES DISTRICT COURT 20 CENTRAL DISTRICT OF CALIFORNIA 21 22 23 CONSTRUCTION LABORERS TRUST FUNDS FOR SOUTHERN CALIFORNIA ADMINISTRATIVE COMPANY, 24 v. Discovery Matters Assigned to Magistrate Judge Alka Sagar Plaintiff, 25 Case No. 2:16-cv-07454-MWF(ASx) 26 27 MORROW-MEADOWS CORPORATION, et al., 28 STIPULATED PROTECTIVE ORDER Defendants, ~9903859.docx 1 Stipulated Protective Order 1 2 3 4 TRUSTEES OF THE SOUTHERN CALIFORNIA IBEW-NECA PENSION PLAN; et al. Intervenors – Defendants, 5 6 Plaintiff 7 Administrative 8 Corporation (“Morrow-Meadows”) and American Contractors Indemnity Co., and 9 Intervenors-Defendants Trustees of the Southern California IBEW-NECA Pension Plan, 10 Construction Company Laborers (“Laborers Trust Funds Trusts”), for Southern Defendants California Morrow-Meadows et al. (“IBEW-NECA Trusts”), through their attorneys, hereby stipulate as follows: 11 1. A. PURPOSES AND LIMITATIONS 12 Discovery in this action is likely to involve production of confidential, 13 proprietary, or private information for which special protection from public disclosure 14 and from use for any purpose other than prosecuting this litigation may be warranted. 15 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 16 Stipulated Protective Order. The parties acknowledge that this Order does not confer 17 blanket protections on all disclosures or responses to discovery and that the protection it 18 affords from public disclosure and use extends only to the limited information or items 19 that are entitled to confidential treatment under the applicable legal principles. The 20 parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated 21 Protective Order does not entitle them to file confidential information under seal; Civil 22 Local Rule 79-5 sets forth the procedures that must be followed and the standards that 23 will be applied when a party seeks permission from the court to file material under seal. 24 B. 25 This action is likely to involve private and confidential identification information 26 (social security numbers) of Morrow-Meadow employees. Through the ongoing audit 27 in this matter, the Laborers Trusts have already reviewed such information. 28 Additionally, the Laborers Trusts have served the IBEW-NECA Trusts with a document ~9903859.docx GOOD CAUSE STATEMENT 2 Stipulated Protective Order 1 demand for certain unredacted reports, submitted by Morrow-Meadows to the IBEW- 2 NECA Trusts, which contain employee social security numbers. This action may also 3 involve information which Morrow-Meadows may claim is confidential. 4 information related to Morrow-Meadows and its employees is generally unavailable to 5 the public, and is entitled to special protection from public disclosure and from use for 6 any purpose other than prosecution of this action is warranted. The 7 Accordingly, to expedite the flow of information, to facilitate the prompt 8 resolution of disputes over confidentiality of discovery materials, to adequately protect 9 information the parties are entitled to keep confidential, to ensure that the parties are 10 permitted reasonable necessary uses of such material in preparation for and in the 11 conduct of trial, to address their handling at the end of the litigation, and serve the ends 12 of justice, a protective order for such information is justified in this matter. It is the 13 intent of the parties that information will not be designated as confidential for tactical 14 reasons and that nothing be so designated without a good faith belief that it has been 15 maintained in a confidential, non-public manner, and there is good cause why it should 16 not be part of the public record of this case. 17 2. DEFINITIONS 18 2.1 Action: This pending federal law suit. 19 2.2 Challenging Party: A Party or Non-Party that challenges the designation of 20 information or items under this Order. 21 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of how 22 it is generated, stored or maintained) or tangible things that qualify for protection under 23 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 24 Statement. 25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 26 support staff). 27 /// 28 /// ~9903859.docx 3 Stipulated Protective Order 1 2.5 Designating Party: A Party or Non-Party that designates information or 2 items 3 “CONFIDENTIAL.” 4 that 2.6 it produces in disclosures or in responses to discovery as Disclosure or Discovery Material: All items or information, regardless of 5 the medium or manner in which it is generated, stored, or maintained (including, among 6 other things, testimony, transcripts, and tangible things), that are produced or generated 7 in disclosures or responses to discovery in this matter. 8 9 10 11 2.7 Expert: A person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this Action. 2.8 House Counsel: Attorneys who are employees of a party to this Action. 12 House Counsel Does not include Outside Counsel of Record or any other outside 13 Counsel. 14 15 2.9 Non-Party: Any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 16 2.10 Outside Counsel of Record: Attorneys who are not employees of a party to 17 this Action but are retained to represent or advise a party to this Action and have 18 appeared in this Action on behalf of that party or are affiliated with a law firm which 19 has appeared on behalf of that party, and includes support staff. 20 2.11 Party: Any party to this Action, including all of its officers, directors, 21 employees, consultants, retained experts, and Outside Counsel of Record (and their 22 support staffs). 23 24 25 2.12 Producing Party: A Party or Non-Party that produces Disclosure or Discovery Material in this Action. 2.13 Professional Vendors: Persons or entities that provide litigation support 26 services 27 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 28 their employees and subcontractors. (e.g., ~9903859.docx photocopying, videotaping, 4 translating, preparing exhibits Stipulated Protective Order or 1 2 2.14 Protected Material: Any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 3 2.15 Receiving Party: A Party that receives Disclosure or Discovery Material 4 from a Producing Party. 5 3. SCOPE 6 The protections conferred by this Stipulation and Order cover not only Protected 7 Material (as defined above), but also (1) any information copied or extracted from 8 Protected Material;(2) all copies, excerpts, summaries, or compilations of Protected 9 Material; and (3) any testimony, conversations, or presentations by Parties or their 10 Counsel that might reveal Protected Material. Any use of Protected Material at trial 11 shall be governed by the orders of the trial judge. This Order does not govern the use of 12 Protected Material at trial. 13 4. DURATION 14 Even after final disposition of this litigation, the confidentiality obligations 15 imposed by this Order shall remain in effect until a Designating Party agrees otherwise 16 in writing or a court order otherwise directs. Final disposition shall be deemed to be the 17 later of (1) dismissal of all claims and defenses in this Action, with or without 18 prejudice; and (2) final judgment herein after the completion and exhaustion of all 19 appeals, rehearings, remands, trials, or reviews of this Action, including the time limits 20 for filing any motions or applications for extension of time pursuant to applicable law. 21 5. 22 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 23 Each Party or Non-Party that designates information or items for protection under this 24 Order must take care to limit any such designation to specific material that qualifies 25 under the appropriate standards. The Designating Party must designate for protection 26 only those parts of material, documents, items, or oral or written communications that 27 qualify so that other portions of the material, documents, items, or communications for 28 /// ~9903859.docx 5 Stipulated Protective Order 1 which protection is not warranted are not swept unjustifiably within the ambit of this 2 Order. 3 Mass, indiscriminate, or routinized designations are prohibited. Designations that 4 are shown to be clearly unjustified or that have been made for an improper purpose 5 (e.g., to unnecessarily encumber the case development processor to impose unnecessary 6 expenses and burdens on other parties) may expose the Designating Party to sanctions. 7 If it comes to a Designating Party’s attention that information or items that it 8 designated for protection do not qualify for protection, that Designating Party must 9 promptly notify all other Parties that it is withdrawing the inapplicable designation. 10 5.2 Manner and Timing of Designations. Except as otherwise provided in this 11 Order, or as otherwise stipulated or ordered, Disclosure Discovery Material that 12 qualifies for protection under this Order must be clearly so designated before the 13 material is disclosed or produced. Designation in conformity with this Order requires: 14 (a) for information in documentary form (other than electronic 15 documents, dealt with below, and excluding transcripts of depositions or other pretrial 16 or trial proceedings), that the Producing Party affix at a minimum, the legend 17 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 18 contains protected material. If only a portion or portions of the material on a page 19 qualifies for protection, the Producing Party also must clearly identify the protected 20 portion(s) (e.g., by making appropriate markings in the margins). A Party or Non-Party 21 that makes original documents available for inspection need not designate them for 22 protection until after the inspecting Party has indicated which documents it would like 23 copied and produced. During the inspection and before the designation, all of the 24 material made available for inspection shall be deemed “CONFIDENTIAL.” After the 25 inspecting Party has identified the documents it wants copied and produced, the 26 Producing Party must determine which documents, or portions thereof, qualify for 27 protection under this Order. Then, before producing the specified documents, the 28 Producing Party must affix the “CONFIDENTIAL legend” to each page that contains ~9903859.docx 6 Stipulated Protective Order 1 Protected Material. If only a portion or portions of the material on a page qualifies for 2 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 3 by making appropriate markings in the margins). 4 (b) for testimony given in depositions that the Designating Party 5 identify the Disclosure or Discovery Material on the record, before the close of the 6 deposition all protected testimony. 7 (c) for information produced in some form other than documentary and 8 for any other tangible items, that the Producing Party affix in a prominent place on the 9 exterior of the container or containers in which the information is stored the legend 10 “CONFIDENTIAL.” 11 protection, the Producing Party, to the extent practicable, shall identify the protected 12 portion(s). 13 (d) If only a portion or portions of the information warrants for information in electronic format, the Producing Party shall, in a 14 separate communication, indicate which portions of the electronic data should be 15 considered “CONFIDENTIAL” (e.g., indicating a column of social security numbers in 16 spreadsheet is “CONFIDENTIAL”). The Producing Party and the Receiving Party 17 shall jointly be responsible for taking reasonable precautions to assure that 18 CONFIDENTIAL information will be protected in the transmission or exchange of 19 electronic data. 20 regulations protecting the privacy of electronic data, including, but not limited to, the 21 Electronic Communications Privacy Act (18 U.S.C. §2510, et. seq.) and the Computer 22 Fraud and Abuse Act (18 U.S.C. §1030, et. seq.) 23 5.3 All Parties shall be responsible for complying with all laws and Inadvertent Failures to Designate. If timely corrected, an inadvertent 24 failure to designate qualified information or items does not, standing alone, waive the 25 Designating Party’s right to secure protection under this Order for such material. Upon 26 timely correction of a designation, the Receiving Party must make reasonable efforts to 27 assure that the material is treated in accordance with the provisions of this Order. 28 /// ~9903859.docx 7 Stipulated Protective Order 1 6. 2 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court’s Scheduling 4 Order. 5 6 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37.1 et seq. 7 6.3 The burden of persuasion in any such challenge proceeding shall be on the 8 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 9 to harass or impose unnecessary expenses and burdens on other parties) may expose the 10 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 11 the confidentiality designation, all parties shall continue to afford the material in 12 question the level of protection to which it is entitled under the Producing Party’s 13 designation until the Court rules of the challenge. 14 7. 15 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 16 disclosed or produced by another Party or by a Non-Party in connection with this 17 Action only for prosecuting, defending, or attempting to settle this Action. 18 Protected Material may be disclosed only to the categories of persons and under the 19 conditions described in this Order. When the Action has been terminated, a Receiving 20 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). Such 21 Protected Material must be stored and maintained by a Receiving Party at a 22 location and in a secure manner that ensures that access is limited to the persons 23 authorized under this Order. 24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 25 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 26 may disclose any information or item designated “CONFIDENTIAL” only to: 27 /// 28 /// ~9903859.docx 8 Stipulated Protective Order 1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 2 employees of said Outside Counsel of Record to whom it is reasonably necessary to 3 disclose the information for this Action; 4 5 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; 6 (c) Experts (as defined in this Order) of the Receiving Party to whom 7 disclosure is reasonably necessary for this Action and who have signed the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (d) the court and its personnel; 10 (e) court reporters and their staff; 11 (f) professional jury or trial consultants, mock jurors, and Professional 12 Vendors to whom disclosure is reasonably necessary for this Action and who have 13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 15 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 16 (h) during their depositions, witnesses, and attorneys for witnesses, in the 17 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 18 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 19 not be permitted to keep any confidential information unless they sign the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 21 by the Designating Party or ordered by the court. Pages of transcribed deposition 22 testimony or exhibits to depositions that reveal Protected Material may be separately 23 bound by the court reporter and may not be disclosed to anyone except as permitted 24 under this Stipulated Protective Order; and (i) 25 any mediator or settlement officer, and their supporting personnel, 26 mutually agreed upon by any of the parties engaged in settlement discussions. 27 /// 28 /// ~9903859.docx 9 Stipulated Protective Order 1 8. PROTECTED MATERIAL SUBPOENED OR ORDERED PRODUCED IN 2 OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation that 4 compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 7 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order to 9 issue in the other litigation that some or all of the material covered by the subpoena or 10 order is subject to this Protective Order. Such notification shall include a copy of this 11 Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued 13 by the Designating Party whose Protected Material may be affected. If the Designating 14 Party timely seeks a protective order, the Party served with the subpoena or court order 15 shall not produce any information designated in this action as “CONFIDENTIAL” 16 before a determination by the court from which the subpoena or order issued, unless the 17 Party has obtained the Designating Party’s permission. The Designating Party shall 18 bear the burden and expense of seeking protection in that court of its confidential 19 material and nothing in these provisions should be construed as authorizing or 20 encouraging a Receiving Party in this Action to disobey a lawful directive from another 21 court. 22 9. A NON-PARTY’S PROTECTED 23 (a) SOUGHT TO BE PRODUCED IN THIS LITIGATION 24 MATERIAL The terms of this Order are applicable to information produced by a Non- 25 Party in this Action and designated as “CONFIDENTIAL.” Such information produced 26 by Non-Parties in connection with this litigation is protected by the remedies and relief 27 provided by this Order. Nothing in these provisions should be construed as prohibiting 28 a Non-Party from seeking additional protections. ~9903859.docx 10 Stipulated Protective Order 1 (b) In the event that a Party is required, by a valid discovery request, to 2 produce a Non-Party’s confidential information in its possession, and the Party is 3 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 4 information, then the Party shall: 5 (1) promptly notify in writing the Requesting Party and the Non-Party 6 that some or all of the information requested is subject to a confidentiality agreement 7 with a Non-Party; 8 9 10 (2) Protective Order in this Action, the relevant discovery request(s), and a reasonably specific description of the information requested; and 11 12 promptly provide the Non-Party with a copy of the Stipulated (3) make the information requested available for inspection by the Non- Party, if requested. 13 (c) If the Non-Party fails to seek a protective order from this court within 14 14 days of receiving the notice and accompanying information, the Receiving Party may 15 produce the Non-Party’s confidential information responsive to the discovery request. If 16 the Non-Party timely seeks a protective order, the Receiving Party shall not produce 17 any information in its possession or control that is subject to the confidentiality 18 agreement with the Non-Party before a determination by the court. Absent a court order 19 to the contrary, the Non-Party shall bear the burden and expense of seeking protection 20 in this court of its Protected Material. 21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 23 Protected Material to an person or in any circumstance not authorized under this 24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 25 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 26 all unauthorized copies of the Protected Material, (c) inform the person or persons to 27 whom unauthorized disclosures were made of all the terms of this Order, and (d) 28 ~9903859.docx 11 Stipulated Protective Order 1 request such person or persons to execute the “Acknowledgment and Agreement to Be 2 Bound” (Exhibit A). 3 11. INADVERTENT PRODUCTION OF PRIVILEGE OR OTHERWISE 4 PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain 6 inadvertently produced material is subject to a claim of privilege or other protection, the 7 obligations of the Receiving Parties are those set forth in Federal Rule of Civil 8 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 9 may be established in an e-discovery order that provides for production without prior 10 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 11 parties reach an agreement on the effect of disclosure of a communication or 12 information covered by the attorney-client privilege or work product protection, the 13 parties may incorporate their agreement in the stipulated protective order submitted to 14 the court. 15 12. 16 17 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. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this 19 Protective Order no Party waives any right it otherwise would have to object to 20 disclosing or producing any information or item on any ground not addressed in this 21 Stipulated Protective Order. Similarly, no Party waives any right to object on any 22 ground to use in evidence of any of the material covered by this Protective Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any 24 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 25 only be filed under seal pursuant to a court order authorizing the sealing of the specific 26 Protected Material at issue. If a Party's request to file Protected Material under seal is 27 denied by the court, then the Receiving Party may file the information in the public 28 record unless otherwise instructed by the court. ~9903859.docx 12 Stipulated Protective Order 1 12.4 Nothing herein is meant to alter or supersede the obligations of counsel to 2 comply with the E-Government Act of 2002, Public Law 107–347, Fed. R. Civ. P. 5.2, 3 and Local Rule 5-2, in filing documents with the Court. 4 12.5 It is recognized that the Laborers Trusts and the IBEW-NECA Trusts are 5 fiduciaries as to employee benefit plans governed by the Employee Retirement Income 6 Security Act (ERISA), 29 U.S.C. §§ 1001, et. seq. As such, they (and other agents and 7 employees of such employee benefit plans) have independent legal obligations under 8 ERISA and other laws regarding reporting, disclosure, use and protection of certain 9 information. Nothing herein is meant to alter or supersede those legal obligations in 10 any way. 11 13. FINAL DISPOSITION 12 After the final disposition of this Action, as defined in paragraph 4, within 60 13 days of a written request by the Designating Party, each Receiving Party must return all 14 Protected Material to the Producing Party or destroy such material. As used in this 15 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 16 summaries, and any other format reproducing or capturing any of the Protected 17 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 18 must submit a written certification to the Producing Party (and, if not the same person 19 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 20 category, where appropriate) all the Protected Material that was returned or destroyed 21 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 22 compilations, summaries or any other format reproducing or capturing any of the 23 Protected Material. Notwithstanding this provision, Counsel are entitle to retain an 24 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 25 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 26 work product, and consultant and expert work product, even if such Materials contain 27 Protected Material. 28 Material remain subject to this Protective Order as set forth in Section 4 (DURATION). ~9903859.docx Any such archival copies that contain or constitute Protected 13 Stipulated Protective Order 1 14. 2 including, without limitation, contempt proceedings and/or monetary sanctions. Any violation of this Order may be punished by any and all appropriate measures 3 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 Dated: December 4, 2017 7 By: /S/ J. David Sackman J. David Sackman, Counsel for Plaintiff, Construction Laborers Trust Funds for Southern California Administrative Company 8 9 10 Dated: December 4, 2017 MCLEOD & WITHAM LLP By: /S/ David S. McLeod David S. McLeod, Counsel for Defendants, Defendants Morrow-Meadows Corporation and American Contractors Indemnity Co. 11 12 13 14 REICH, ADELL & CVITAN, APC Dated: December 4, 2017 LAQUER, URBAN, CLIFFORD & HODGE LLP By: /S/ J. Paul Moorhead J. Paul Moorhead, Counsel for Intervenors – Defendants, Trustees of the Southern California IBEW-NECA Pension Plan, et. al. 15 16 17 18 19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 20 21 December 6, 2017 Dated: ___________________ / s / Alka Sagar _______________________________ Honorable Alka Sagar United States Magistrate Judge 22 23 24 25 26 27 28 ~9903859.docx 14 Stipulated Protective Order 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, ________________ [print or type full name], of ______________________________ 5 [print or type full address], declare under penalty of perjury that I have read in its 6 entirety and understand the Stipulated Protective Order that was issued by the United 7 States District Court for the Central District of California on [date] in the case of 8 Construction Laborers Trust Funds for Southern California Administrative Company v. 9 Morrow-Meadows Corporation, et al., USDC Case No. 2:16-cv-07454-MWF(ASx). I 10 agree to comply with and to be bound by all the terms of this Stipulated Protective 11 Order and I understand and acknowledge that failure to so comply could expose me to 12 sanctions and punishment in the nature of contempt. I solemnly promise that I will not 13 disclose in any manner any information or item that is subject to this Stipulated 14 Protective Order to any person or entity except in strict compliance with the provisions 15 of this Order. I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceeding occur after 18 termination of this action. I hereby appoint _______________ [print or type full name] 19 of ____________________________ [print or type full address and telephone number] 20 as my California agent for service of proceedings connection with this action or any 21 proceedings related to enforcement of this Stipulated Protective Order. 22 23 Date: __________________ 24 City and State where sworn and signed: ________________________________ 25 Printed name: _________________________________ 26 Signature: _________________________________ 27 28 ~9903859.docx 15 Stipulated Protective Order

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