Brian Patterson v. The Boeing Company et al

Filing 31

PROTECTIVE ORDER by Magistrate Judge Steve Kim. In re: Stipulation for Protective Order, 29 . (mkr)

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1 2 3 4 5 6 7 8 9 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12 13 BRIAN PATTERSON, an individual, Plaintiff, 14 17 18 19 20 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER vs. 15 16 Case No. 2:16-CV-07613-GW-SK THE BOEING COMPANY, a Delaware Corporation; BOEING DEFENSE, SPACE & SECURITY, a division of BOEING, business entity form unknown; BOEING NETWORK & SPACE SYSTEMS, a part of BOEING DEFENSE, SPACE & SECURITY, a business entity, form unknown and DOES 1-10; Defendants. 21 22 23 24 25 26 27 28 MORGAN, LEWIS & BOCKIUS LLP ATTORNEYS AT LAW LOS ANGELES DB2/ 31597557.1 1 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 Plaintiff Brian Patterson (“Plaintiff”), and Defendants The Boeing Company, 1 2 Boeing Defense, Space & Security and Boeing Network & Space Systems 3 (“Defendants”) (collectively, the “Parties”), by and through their respective 4 counsel, hereby stipulate and agree as follows: 5 1. 6 A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, 7 proprietary, or private information for which special protection from public 8 disclosure and from use for any purpose other than prosecuting this litigation may 9 be warranted. Accordingly, the Parties hereby stipulate to and petition the Court to 10 enter the following Stipulated Protective Order. The Parties acknowledge that this 11 Order does not confer blanket protections on all disclosures or responses to 12 discovery and that the protection it affords from public disclosure and use extends 13 only to the limited information or items that are entitled to confidential treatment 14 under the applicable legal principles. The Parties further acknowledge, as set forth 15 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 16 file confidential information under seal; Civil Local Rule 79-5 sets forth the 17 procedures that must be followed and the standards that will be applied when a 18 party seeks permission from the court to file material under seal. 19 B. GOOD CAUSE STATEMENT 20 This action is likely to involve trade secrets, customer and pricing lists and 21 other valuable research, development, commercial, financial, technical and/or 22 proprietary information, as well as sensitive personal information regarding private 23 individuals, for which special protection from public disclosure and from use for 24 any purpose other than prosecution of this action is warranted. Such confidential 25 and proprietary materials and information consist of, among other things, 26 confidential business or financial information, information regarding confidential 27 business practices, or other confidential research, development, or commercial 28 information (including information implicating privacy rights of third parties), MORGAN, LEWIS & BOCKIUS LLP 2 ATTORNEYS AT LAW SILICON VALLEY DB2/ 31597557.1 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 1 information otherwise generally unavailable to the public, or which may be 2 privileged or otherwise protected from disclosure under state or federal statutes, 3 court rules, case decisions, or common law. Accordingly, to expedite the flow of 4 information, to facilitate the prompt resolution of disputes over confidentiality of 5 discovery materials, to adequately protect information the Parties are entitled to 6 keep confidential, to ensure that the Parties are permitted reasonable necessary uses 7 of such material in preparation for and in the conduct of trial, to address their 8 handling at the end of the litigation, and serve the ends of justice, a protective order 9 for such information is justified in this matter. It is the intent of the parties that 10 information will not be designated as confidential for tactical reasons and that 11 nothing be so designated without a good faith belief that it has been maintained in a 12 confidential, non-public manner, and there is good cause why it should not be part 13 of the public record of this case. 14 2. 15 16 17 18 19 DEFINITIONS 2.1 Action: Brian Patterson v. The Boeing Company, et al., CASE NO. 16- CV-07613. 2.2 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 20 how it is generated, stored or maintained) or tangible things that qualify for 21 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 22 the Good Cause Statement. 23 24 25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 2.5 Designating Party: a Party or Non-Party that designates information or 26 items that it produces in disclosures or in responses to discovery as 27 “CONFIDENTIAL.” 28 MORGAN, LEWIS & BOCKIUS LLP 3 ATTORNEYS AT LAW SILICON VALLEY DB2/ 31597557.1 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 1 2.6 Disclosure or Discovery Material: all items or information, regardless 2 of the medium or manner in which it is generated, stored, or maintained (including, 3 among other things, testimony, transcripts, and tangible things), that are produced 4 or generated in disclosures or responses to discovery in this matter. 5 2.7 Expert: a person with specialized knowledge or experience in a matter 6 pertinent to the litigation who has been retained by a Party or its counsel to serve as 7 an expert witness or as a consultant in this Action. 8 9 10 11 12 2.8 House Counsel: attorneys who are employees of a party to this Action. House Counsel does not include Outside Counsel of Record or any other outside counsel. 2.9 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 13 2.10 Outside Counsel of Record: attorneys who are not employees of a 14 party to this Action but are retained to represent or advise a party to this Action and 15 have appeared in this Action on behalf of that party or are affiliated with a law firm 16 which has appeared on behalf of that party, and includes support staff. 17 2.11 Party: any party to this Action, including all of its officers, directors, 18 employees, consultants, retained experts, and Outside Counsel of Record (and their 19 support staffs). 20 21 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 22 2.13 Professional Vendors: persons or entities that provide litigation 23 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 24 demonstrations, and organizing, storing, or retrieving data in any form or medium) 25 and their employees and subcontractors. 26 27 28 2.14 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 2.15 Receiving Party: a Party that receives Disclosure or Discovery MORGAN, LEWIS & BOCKIUS LLP 4 ATTORNEYS AT LAW SILICON VALLEY DB2/ 31597557.1 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 1 Material from a Producing Party. 2 3. SCOPE 3 The protections conferred by this Stipulation and Order cover not only 4 Protected Material (as defined above), but also (1) any information copied or 5 extracted from Protected Material; (2) all copies, excerpts, summaries, or 6 compilations of Protected Material; and (3) any testimony, conversations, or 7 presentations by Parties or their Counsel that might reveal Protected Material. Any 8 use of Protected Material at trial shall be governed by the orders of the trial judge. 9 This Order does not govern the use of Protected Material at trial. 10 4. DURATION 11 Even after final disposition of this litigation, the confidentiality obligations 12 imposed by this Order shall remain in effect until a Designating Party agrees 13 otherwise in writing or a court order otherwise directs. Final disposition shall be 14 deemed to be the later of (1) dismissal of all claims and defenses in this Action, 15 with or without prejudice; and (2) final judgment herein after the completion and 16 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 17 including the time limits for filing any motions or applications for extension of time 18 pursuant to applicable law. 19 5. DESIGNATING PROTECTED MATERIAL 20 5.1 Exercise of Restraint and Care in Designating Material for Protection. 21 Each Party or Non-Party that designates information or items for protection 22 under this Order must take care to limit any such designation to specific material 23 that qualifies under the appropriate standards. The Designating Party must 24 designate for protection only those parts of material, documents, items, or oral or 25 written communications that qualify so that other portions of the material, 26 documents, items, or communications for which protection is not warranted are not 27 swept unjustifiably within the ambit of this Order. 28 MORGAN, LEWIS & BOCKIUS LLP 5 ATTORNEYS AT LAW SILICON VALLEY DB2/ 31597557.1 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 1 Mass, indiscriminate, or routinized designations are prohibited. Designations 2 that are shown to be clearly unjustified or that have been made for an improper 3 purpose (e.g., to unnecessarily encumber the case development process or to 4 impose unnecessary expenses and burdens on other parties) may expose the 5 Designating Party to sanctions. 6 If it comes to a Designating Party’s attention that information or items that it 7 designated for protection do not qualify for protection, that Designating Party must 8 promptly notify all other Parties that it is withdrawing the inapplicable designation. 9 5.2 Manner and Timing of Designations. Except as otherwise provided in 10 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 11 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 12 under this Order must be clearly so designated before the material is disclosed or 13 produced. 14 Designation in conformity with this Order requires: 15 (a) for information in documentary form (e.g., paper or electronic 16 documents, but excluding transcripts of depositions or other pretrial or trial 17 proceedings), that the Producing Party affix at a minimum, the legend 18 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 19 contains protected material. If only a portion or portions of the material on a page 20 qualifies for protection, the Producing Party also must clearly identify the protected 21 portion(s) (e.g., by making appropriate markings in the margins). A Party or Non- 22 Party that makes original documents available for inspection need not designate 23 them for protection until after the inspecting Party has indicated which documents it 24 would like copied and produced. During the inspection and before the designation, 25 all 26 “CONFIDENTIAL.” After the inspecting Party has identified the documents it 27 wants copied and produced, the Producing Party must determine which documents, 28 or portions thereof, qualify for protection under this Order. Then, before producing of the MORGAN, LEWIS & BOCKIUS LLP made available 6 ATTORNEYS AT LAW SILICON VALLEY material DB2/ 31597557.1 for inspection shall be deemed [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 1 the specified documents, the Producing Party must affix the “CONFIDENTIAL 2 legend” to each page that contains Protected Material. If only a portion or portions 3 of the material on a page qualifies for protection, the Producing Party also must 4 clearly identify the protected portion(s) (e.g., by making appropriate markings in 5 the margins). 6 (b) for testimony given in depositions that the Designating Party identify 7 the Disclosure or Discovery Material on the record, before the close of the 8 deposition all protected testimony. 9 (c) for information produced in some form other than documentary and 10 for any other tangible items, that the Producing Party affix in a prominent place on 11 the exterior of the container or containers in which the information is stored the 12 legend “CONFIDENTIAL.” If only a portion or portions of the information 13 warrants protection, the Producing Party, to the extent practicable, shall identify the 14 protected portion(s). 15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 16 failure to designate qualified information or items does not, standing alone, waive 17 the Designating Party’s right to secure protection under this Order for such 18 material. Upon timely correction of a designation, the Receiving Party must make 19 reasonable efforts to assure that the material is treated in accordance with the 20 provisions of this Order. 21 6. 22 CHALLENGING CONFIDENTIALITY DESIGNATIONS . 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 23 designation of confidentiality at any time that is consistent with the Court’s 24 Scheduling Order. 25 26 27 28 6.2 dispute resolution process under Local Rule 37.1 et seq. 6.3 The burden of persuasion in any such challenge proceeding shall be on the Designating Party. Frivolous challenges, and those made for an improper MORGAN, LEWIS & BOCKIUS LLP 7 ATTORNEYS AT LAW SILICON VALLEY Meet and Confer. The Challenging Party shall initiate the DB2/ 31597557.1 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 1 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 2 parties) may expose the Challenging Party to sanctions. Unless the Designating 3 Party has waived or withdrawn the confidentiality designation, all parties shall 4 continue to afford the material in question the level of protection to which it is 5 entitled under the Producing Party’s designation until the Court rules on the 6 challenge. 7 7. 8 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 9 disclosed or produced by another Party or by a Non-Party in connection with this 10 Action only for prosecuting, defending, or attempting to settle this Action. Such 11 Protected Material may be disclosed only to the categories of persons and under 12 the conditions described in this Order. When the Action has been terminated, a 13 Receiving Party must comply with the provisions of section 13 below (FINAL 14 DISPOSITION). 15 Protected Material must be stored and maintained by a Receiving Party at a 16 location and in a secure manner that ensures that access is limited to the persons 17 authorized under this Order. 18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 19 otherwise ordered by the court or permitted in writing by the Designating Party, a 20 Receiving 21 “CONFIDENTIAL” only to: Party may disclose any information or item designated 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 23 well as employees of said Outside Counsel of Record to whom it is reasonably 24 necessary to disclose the information for this Action; (b) the officers, directors, and employees (including House Counsel) of 25 26 the Receiving Party to whom disclosure is reasonably necessary for this Action; 27 28 MORGAN, LEWIS & BOCKIUS LLP 8 ATTORNEYS AT LAW SILICON VALLEY DB2/ 31597557.1 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 1 (c) Experts (as defined in this Order) of the Receiving Party to whom 2 disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (d) the court and its personnel; 5 (e) court reporters and their staff; 6 (f) professional jury or trial consultants, mock jurors, and Professional 7 Vendors to whom disclosure is reasonably necessary for this Action and who have 8 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 10 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 11 (h) during their depositions, witnesses, and attorneys for witnesses, in 12 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 13 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 14 they will not be permitted to keep any confidential information unless they sign the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 16 agreed by the Designating Party or ordered by the court. Pages of transcribed 17 deposition testimony or exhibits to depositions that reveal Protected Material may 18 be separately bound by the court reporter and may not be disclosed to anyone 19 except as permitted under this Stipulated Protective Order; and 20 (i) any mediator or settlement officer, and their supporting personnel, 21 mutually agreed upon by any of the parties engaged in settlement discussions. 22 8. 23 IN OTHER LITIGATION PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 24 If a Party is served with a subpoena or a court order issued in other litigation 25 that compels disclosure of any information or items designated in this Action as 26 “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification 27 28 shall include a copy of the subpoena or court order; MORGAN, LEWIS & BOCKIUS LLP 9 ATTORNEYS AT LAW SILICON VALLEY DB2/ 31597557.1 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 1 (b) promptly notify in writing the party who caused the subpoena or 2 order to issue in the other litigation that some or all of the material covered by the 3 subpoena or order is subject to this Protective Order. Such notification shall 4 include a copy of this Stipulated Protective Order; and 5 6 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 7 If the Designating Party timely seeks a protective order, the Party served with 8 the subpoena or court order shall not produce any information designated in this 9 action as “CONFIDENTIAL” before a determination by the court from which the 10 subpoena or order issued, unless the Party has obtained the Designating Party’s 11 permission. The Designating Party shall bear the burden and expense of seeking 12 protection in that court of its confidential material and nothing in these provisions 13 should be construed as authorizing or encouraging a Receiving Party in this Action 14 to disobey a lawful directive from another court. 15 9. 16 PRODUCED IN THIS LITIGATION A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 17 (a) The terms of this Order are applicable to information produced by a 18 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 19 produced by Non-Parties in connection with this litigation is protected by the 20 remedies and relief provided by this Order. Nothing in these provisions should be 21 construed as prohibiting a Non-Party from seeking additional protections. 22 (b) In the event that a Party is required, by a valid discovery request, to 23 produce a Non-Party’s confidential information in its possession, and the Party is 24 subject to an agreement with the Non-Party not to produce the Non-Party’s 25 confidential information, then the Party shall: 26 (1) promptly notify in writing the Requesting Party and the Non- 27 Party that some or all of the information requested is subject to a confidentiality 28 agreement with a Non-Party; MORGAN, LEWIS & BOCKIUS LLP 10 ATTORNEYS AT LAW SILICON VALLEY DB2/ 31597557.1 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 1 (2) promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this Action, the relevant discovery request(s), and a reasonably 3 specific description of the information requested; and 4 5 (3) make the information requested available for inspection by the Non-Party, if requested. 6 (c) If the Non-Party fails to seek a protective order from this court within 7 14 days of receiving the notice and accompanying information, the Receiving Party 8 may produce the Non-Party’s confidential information responsive to the discovery 9 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 10 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. 12 Absent a court order to the contrary, the Non-Party shall bear the burden and 13 expense of seeking protection in this court of its Protected Material. 14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 16 Protected Material to any person or in any circumstance not authorized under this 17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 18 writing the Designating Party of the unauthorized disclosures, (b) use its best 19 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 20 person or persons to whom unauthorized disclosures were made of all the terms of 21 this Order, and (d) request such person or persons to execute the “Acknowledgment 22 and Agreement to Be Bound” that is attached hereto as Exhibit A. 23 11. 24 PROTECTED MATERIAL INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 25 When a Producing Party gives notice to Receiving Parties that certain 26 inadvertently produced material is subject to a claim of privilege or other 27 protection, the obligations of the Receiving Parties are those set forth in Federal 28 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify MORGAN, LEWIS & BOCKIUS LLP 11 ATTORNEYS AT LAW SILICON VALLEY DB2/ 31597557.1 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 1 whatever procedure may be established in an e-discovery order that provides for 2 production without prior privilege review. Pursuant to Federal Rule of Evidence 3 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 4 of a communication or information covered by the attorney-client privilege or work 5 product protection, the Parties may incorporate their agreement in the stipulated 6 protective order submitted to the court. 7 12. 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 8 9 MISCELLANEOUS person to seek its modification by the Court in the future. 10 12.2 Right to Assert Other Objections. By stipulating to the entry of this 11 Protective Order no Party waives any right it otherwise would have to object to 12 disclosing or producing any information or item on any ground not addressed in 13 this Stipulated Protective Order. Similarly, no Party waives any right to object on 14 any ground to use in evidence of any of the material covered by this Protective 15 Order. 16 12.3 Filing Protected Material. A Party that seeks to file under seal any 17 Protected Material must comply with Civil Local Rule 79-5. Protected Material 18 may only be filed under seal pursuant to a court order authorizing the sealing of the 19 specific Protected Material at issue. If a Party's request to file Protected Material 20 under seal is denied by the court, then the Receiving Party may file the information 21 in the public record unless otherwise instructed by the court. 22 13. FINAL DISPOSITION 23 After the final disposition of this Action, as defined in paragraph 4, within 60 24 days of a written request by the Designating Party, each Receiving Party must 25 return all Protected Material to the Producing Party or destroy such material. As 26 used in this subdivision, “all Protected Material” includes all copies, abstracts, 27 compilations, summaries, and any other format reproducing or capturing any of the 28 Protected Material. Whether the Protected Material is returned or destroyed, the MORGAN, LEWIS & BOCKIUS LLP 12 ATTORNEYS AT LAW SILICON VALLEY DB2/ 31597557.1 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 1 Receiving Party must submit a written certification to the Producing Party (and, if 2 not the same person or entity, to the Designating Party) by the 60 day deadline that 3 (1) identifies (by category, where appropriate) all the Protected Material that was 4 returned or destroyed and (2) affirms that the Receiving Party has not retained any 5 copies, abstracts, compilations, summaries or any other format reproducing or 6 capturing any of the Protected Material. Notwithstanding this provision, Counsel 7 are entitled to retain an archival copy of all pleadings, motion papers, trial, 8 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 9 and trial exhibits, expert reports, attorney work product, and consultant and expert 10 work product, even if such materials contain Protected Material. Any such archival 11 copies that contain or constitute Protected Material remain subject to this Protective 12 Order as set forth in Section 4 (DURATION). 13 14. 14 measures including, without limitation, contempt proceedings and/or monetary 15 sanctions. Any violation of this Order may be punished by any and all appropriate 16 17 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 18 19 DATED: June 21, 2017 20 21 22 23 24 Honorable Steve Kim United States Magistrate Judge 25 26 27 28 MORGAN, LEWIS & BOCKIUS LLP 13 ATTORNEYS AT LAW SILICON VALLEY DB2/ 31597557.1 [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613 1 2 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of [print or type full address], declare under 4 penalty of perjury that I have read in its entirety and understand the Stipulated 5 Protective Order that was issued by the United States District Court for the Central 6 District of California on [date] in the case of Brian Patterson v. The Boeing 7 Company, et al., CASE NO. 16-CV-07613. I agree to comply with and to be bound 8 by all the terms of this Stipulated Protective Order and I understand and 9 acknowledge that failure to so comply could expose me to sanctions and punishment 10 in the nature of contempt. I solemnly promise that I will not disclose in any manner 11 any information or item that is subject to this Stipulated Protective Order to any 12 person or entity except in strict compliance with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court 14 for the Central District of California for the purpose of enforcing the terms of this 15 Stipulated Protective Order, even if such enforcement proceedings occur after 16 termination of this action. I hereby appoint [print or type full name] of [print or 17 type full address and telephone number] as my California agent for service of 18 process in connection with this action or any proceedings related to enforcement of 19 this Stipulated Protective Order. 20 Date: ________________________ 21 City and State where sworn and signed: ______________________________ 22 23 24 Printed name: ____________________________________ Signature: __________________________________________ 25 26 27 28 MORGAN, LEWIS & BOCKIUS LLP 14 ATTORNEYS AT LAW LOS ANGELES DB2/ 31597557.1 STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-07613

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