Online Flower Search, LLC v. Floralship, Inc., et al

Filing 30

PROTECTIVE ORDER by Magistrate Judge Charles F. Eick re Stipulation for Protective Order 29 . (sp)

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CasE X2:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 1 of 16 Page ID #:116 (SBN 125119) 1 DON A. HERNANDEZ, 2 ZUBER LAWL R &DEL DUCA LLP 777 S. Figueroa Street, 37th Floor 3 Los Angeles, California 90017 USA Telephone: (213)596-5620 4 Facsimile: (213)596-5621 5 Attorneys for Plaintiff ONLINE FLOWER SEARCH,LLC 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA,WESTERN DIVISION 10 ~ ONLINE FLOWER SEARCH,LLC, Plaintiff, 11 12 Case No. 2:16-cv-08773-GW-E Assigned to Hon. George H. Wu, ourtroom 9I?] v. DISCOVERY MATTER 13 FLORALSHIP,INC. and CHARLES M. JACKSON, 14 ROTECTI STIPULATED ORDER Defendants. 15 Trial Date: None Set 16 17 Plaintiff Online Flower Search, LLC ("Plaintiff') and Defendants Floralship, 18 Inc. and Charles M. Jackson ("Defendants")(each ofthe Plaintiffs and Defendants are 19 individually referred to as a "Party" and all Plaintiffs and Defendants are referred to 2 as "Parties"), by and through the undersigned counsel, hereby agree that information 0 21 disclosed by any Party or Non-Party witness during this proceeding may be 22 considered(1) CONFIDENTIAL or(2) CONFIDENTIAL —FOR ATTORNEYS' 23 EYES ONLY (trade secret/ commercially sensitive) by a Party or Non-Party 24 Witness. To preserve the confidentiality ofthe information so disclosed, the Parties 2 are hereby bound by the terms ofthis Order. As used in this Order, the term 5 2 " 6 Information" covers documentary material, electronically stored information 27 ( "ESI"), testimony, and any other information provided during the course of this 2 action. 8 F c..~av:~y~cs~ccy~ i z Case No. 2:16-cv-08773-GW-E [ PROPOSED]STIPULATED PROTECTIVE ORDER 2:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 2 of 16 Page ID #:117 1 This Order shall govern any Information produced in this action and 2 designated pursuant to this Order, including all designated discovery depositions, 3 all designated testimony depositions and declarations and affidavits, all designated 4 deposition e~chibits and testimony e~ibits,interrogatory answers,admissions, 5 ~ ~ documents and other discovery and testimony materials, whether produced 6 ~ ~ informally, as part of mandatory disclosures, or in response to interrogatories, 7 ~ ~ requests for admissions, requests for production of documents or other methods of 8 discovery. ~ ~ This Order shall also govern any designated Information produced or provided 10 in this action pursuant to required disclosures under any applicable federal procedural 11 rule and any supplementary disclosures thereto. 12 This Order shall apply to the Parties and to any Non-Party from whom 13 discovery or testimony may be sought in connection with this proceeding and who 14 ~ desires the protection ofthis Order. TERMS OF ORDER 15 16 1 ) Classes of Protected Information. The terms ofthis Order are not to be 17 ~ used to undermine public access to files. When appropriate, however, a Party or Non18 Party Witness, on its own or through its Attorneys, may seek to protect the 19 confidentiality ofInformation by employing one ofthe following designations. 2 0 a . 21 22 CONFIDENTIAL —Material to be shielded by the Court, the Parties and the Parties' Attorneys from public access. b. CONFIDENTIAL —ATTORNEYS'EYES ONLY(Trade 2 Secret/Commercially Sensitive) —Material to be shielded by the Court and the 3 24 Parties' outside counsel from public access, restricted from any access by the Parties, 2 and available for review by outside counsel, but not in-house counsel,for the Parties 5 2 and, subject to the provisions of paragraphs 4 and 5, by Independent Experts or 6 2 Consultants for the Parties. Such material may include the following types of 7 28~ Information: (1)sensitive technical information, including current research, 2460-] 002 / 677067.1 Case No. 2:16-cv-08773-GW-E [ PROPOSED]STIPULATED PROTECTIVE ORDER 2:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 3 of 16 Page ID #:118 1 ~~ development and manufacturing information;(2)sensitive business information, 2 ~ ~ including highly sensitive financial or marketing information;(3)competitive 3 ~ ~ technical information, including technical analyses or comparisons of competitor's 4 ~I products or services;(4)competitive business information, including non-public 5 ~ ~ financial and marketing analyses, media scheduling, comparisons of competitor's 6 II products or services, and strategic product/service expansion plans;(5)personal 7 ~ ~ health or medical information;(6) an individual's personal credit, banking or other 8 f inancial information; or (7) any other commercially sensitive information the I~ disclosure of which to non-qualified persons subject to this Order the producing 10 Party reasonably and in good faith believes would likely cause harm. 11 2 ) Information Not to be Designated as Protected. Information may not 12 ~~ be designated as subject to any form of protection if it: (a)is, or becomes, public 13 knowledge, as shown by publicly available writings, other than through violation of 14 the terms of this Order;(b)is acquired by anon-designating Party or Non-Party 15 Witness from a third party lawfully possessing such Information and having no 16 obligation to the owner ofthe Information;(c) was lawfully possessed by a non17 designating Party or Non-Party Witness prior to the opening of discovery in this 18 proceeding, and for which there is written evidence ofthe lawful possession;(d)is 19 disclosed by anon-designating Party or Non-Party Witness legally compelled to 2 disclose the information; or(e)is disclosed by anon-designating Party with the 0 21 approval ofthe designating Party. 22 3 ) Access to Protected Information. The provisions ofthis Order 23 ~~ regarding access to protected Information are subject to modification by written 24 agreement of the Parties or their Attorneys and approved by the Court. Court 25 reporters, stenographers, video technicians or others who may be employed by the 2 Parties or their Attorneys to perform services incidental to this action will be bound 6 27 only to the extent that the Parties or their Attorneys make it a condition of 2 /// 8 2460-1002/677067.1 Case No.2:16-cv-08773-GW-E [ PROPOSED]STIPULATED PROTECTIVE ORDER 2:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 4 of 16 Page ID #:119 1 employment or obtain agreements from such individuals, in accordance with the 2 I, provisions of paragraph 4. 3 • Parties are defined as including individuals, officers of corporations, 4 partners of partnerships, members of limited liability 5 companies/corporations, and management employees of any type of 6 business organization ofthe Plaintiffs and Defendants. 7 • Attorneys for Parties are defined as including in-house counsel and 8 outside counsel, including support staff operating under counsel's 9 direction, such as paralegals or legal assistants, secretaries, and any 10 other employees or independent contractors operating under counsel's 11 instruction. 12 • Independent Experts or Consultants include individuals retained by a 13 Party for purposes related to prosecution or defense of the action but 14 who are not current or former employees, officers, members, directors, 15 or partners of any Party, affiliates of any Party, or the Attorneys of any 16 Party or its affiliates, or competitors to any Party, or employees or 17 consultants ofsuch competitors with respect to the subject matter ofthe 18 action. 19 • Non-Party Witnesses include any individuals to be deposed during 2 0 discovery or trial, whether willingly or under subpoena issued by a 21 court of competent jurisdiction over the witness. 22 Parties and their Attorneys shall have access to information designated as 2 CONFIDENTIAL,subject to any agreed exceptions. Outside counsel, but not in3 24 house counsel,shall have access to information designated as CONFIDENTIAL — 25 ATTORNEYS'EYES ONLY(trade secret/commercially sensitive). Independent 2 Experts or Consultants, Non-Party Witnesses, and any other individual not 6 27 otherwise specifically covered by the terms of this Order may be afforded access to 2 Confidential information in accordance with the terms that follow in paragraph 4. 8 t } 2460-1002 / 677067.1 Case No.2:16-cv-08773-GW-E [ PROPOSED]STIPULATED PROTECTIVE ORDER 2:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 5 of 16 Page ID #:120 1 Further, Independent Experts or Consultants may have access to 2 ~ CONFIDENTIAL —ATTORNEYS'EYES ONLY (trade secret/commercially 3 ~ sensitive)information ifsuch access is agreed to by the Parties or ordered by the 4 ~ Court, in accordance with the terms that follow in paragraphs 4 and 5. 5 4 ) Disclosure to Any Individual. Prior to disclosure of protected 6 Information by any Party or its Attorney to any individual not already provided 7 access to such Information by the terms ofthis Order,the individual shall be informed 8 of the existence of this Order and provided with a copy to read. The individual will 9 then be required to certify in writing that the Order has been read and understood and 10 that the terms shall be binding on the individual. No individual shall receive any 11 protected Information until the Pariy or Attorney proposing to disclose the 12 information has received a signed certification from the individual. A form for 13 such certification, entitled Certificate of Compliance, is attached to this Order. See 14 Exhibit A. The Party or Attorney receiving the completed form shall retain the 15 original. 16 5 ) Disclosure to Independent Experts or Consultants. In addition to 17 meeting the requirements of paragraph 4, any Party or Attorney proposing to share 18 disclosed Information with an Independent Expert or Consultant must also notify the 19 Party who designated the Information as protected. Notification must be personally 2 served or forwarded by certified mail, return receipt requested, or by email, and shall 0 21 provide notice of the name, address, occupation and professional background ofthe 2 Independent Expert or Independent Consultant. 2 2 3 The Party or its Attorney receiving the notice shall have ten(10)business days to 24~ object to disclosure to the Independent Expert or Independent Consultant. If 2 objection is made, then the Parties must negotiate the issue in good faith before 5 2 raising the issue before the Court. Ifthe Parties are unable to settle their dispute, then 6 27 it shall be the obligation ofthe Party or Attorney proposing disclosure to bring the 2 matter before the Court with an explanation ofthe need for disclosure and a report on 8 II 2460-1002/677067.1 5 Case No. 2:16-cv-08773-GW-E [PROPOSED]STIPULATED PROTECTIVE ORDER Cas~~2:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 6 of 16 Page ID #:121 1 the efforts the Parties have made to settle their dispute. The Pariy objecting to 2 disclosure will be expected to respond with its arguments against disclosure or its 3 I ~ objections will be deemed waived. 4 6 ) Responses to Written Discovery. Responses to interrogatories under 5 Federal Rule 33 and requests for admissions under Federal Rule 36 (whether in a 6 paper or electronic form) and which the responding Pariy reasonably believes to 7 contain protected Information shall be prominently stamped or marked with the 8 appropriate designation from paragraph 1. Any inadvertent disclosure without 9 appropriate designation shall be remedied as soon as the disclosing Party learns of its 10 error, by informing all adverse Parties, in writing, of the error. The Parties should 11 inform the Court only if necessary because of the filing of protected Information not 12 in accordance with the provisions of paragraph 9. 13 7 ) Production of Documents. Ifa Party responds to requests for production 14 under Federal Rule 34 by making copies and forwarding the copies to the inquiring 15 Party, including ESI, then the copies shall be prominently stamped or marked, as 16 necessary, with the appropriate designation from paragraph 1. If the responding 17 Party makes documents available for inspection and copying by the inquiring Party, 18 all documents shall be considered protected during the course of inspection. After 19 the inquiring Party informs the responding Party what documents are to be copied, 2 the responding Party will be responsible for prominently stamping or marking the 0 21 copies with the appropriate designation from paragraph 1. 2 2 8 ) Depositions. Protected documents produced during an oral discovery 2 ~ deposition or a discovery deposition upon written questions, or offered into 3 24 evidence during an oral testimony deposition, a testimony deposition upon written 2 questions, or testimony submitted by affidavit or declaration, shall be noted 5 2 appropriately as such by the producing or offering Party at the outset of any 6 27 discussion ofthe document or Information contained in the document. In addition, 28 /// 2460-1002/677067.1 Case No. 2:16-cv-08773-GW-E [ PROPOSED]STIPULATED PROTECTIVE ORDER X2:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 7 of 16 Page ID #:122 1 ~~ the documents must be prominently stamped or marked with the appropriate 2 ~ ~ designation. 3 During discussion of any non-documentary protected Information, the 4 interested Party shall make oral note on the record ofthe protected nature ofthe 5 Information. 6 The transcript ofany deposition(whether for discovery or testimony purposes) 7 and all exhibits or attachments shall be considered protected for 30 days following 8 the date of service ofthe transcript by the Party that took the deposition. During that 9 30-day period, either Party may designate the portions of the transcript, and any 10 specific e~ibits or attachments,that are to be treated as protected, by electing the 11 appropriate designation from paragraph 1. Appropriate stampings or markings should 12 be made during this time, if not already done so. If no such designations are made, 13 then the entire transcript and exhibits will be considered unprotected. 14 9 ) Briefs. When filing briefs, memoranda, affidavits and/or declarations in 15 support of a motion, or briefs at final hearing, the portions ofthese filings that discuss 16 protected information, whether information ofthe filing party, or any adverse party, 17 or any non-party witness, should be redacted. The rule of reasonableness for redaction 18 is discussed in paragraph 12 ofthis Order. 19 10) Handling of Protected Information. Disclosure ofInformation 2 protected under the terms of this Order is intended only to facilitate the prosecution or 0 21 defense of this action. The recipient of any protected Information disclosed in 22 accordance with the terms of this Order is obligated to maintain the confidentiality 2 the Information and shall exercise reasonable care in handling, storing, using, 3 24 disseminating, retaining, returning, and destroying the information. 2 5 11) Redaction; Filing Material with the Court. When a party or attorney 2 must file protected information with the Court, or a motion or final brief that 6 27 discusses such information, the protected information or portion ofthe motion/brief 2 /// 8 2460-1002/677067.1 Case No. 2:16-cv-08773-GW-E [ PROPOSED]STIPULATED PROTECTIVE ORDER 2:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 8 of 16 Page ID #:123 1 ~ discussing the same should be redacted from the remainder. A rule of reasonableness 2 should dictate how redaction is effected. 3 Redaction can entail merely covering or omitting a portion of a page of 4 material when it is copied or printed in anticipation offiling but can also entail the 5 more extreme measure of simply filing the entire page under seal as one that contains 6 primarily confidential material. If only a sentence or short paragraph of a page of 7 ~ material is confidential, covering that material when the page is copied, or omitting 8 the material, would be appropriate. 9 In contrast, if most ofthe material on the page is confidential, then filing the 10 entire page under seal would be more reasonable, even if some small quantity of non11 confidential material is then withheld from the public record. Likewise, when a multi12 page document is in issue, reasonableness would dictate that redaction ofthe portions 13 or pages containing confidential material be effected when only some small number 14~ of pages contain such material. In contrast, if almost every page ofthe document 15 contains some confidential material, it may be more reasonable to simply submit the 16 entire document under seal. Occasions when a whole document or motion/brief 17 must 6e submitted under seal should be very rare. 18 Protected information, and pleadings, briefs or memoranda that reproduce, 19 ~ discuss or paraphrase such information, shall be filed with the Court under seal. If 2 f 0 iled by mail, the envelopes or containers shall be prominently stamped or marked 21 with a legend in substantially the following form: 2 2 CONFIDENTIAL 2 3 This envelope contains documents or information that are subject to a 24 protective order or agreement. The confidentiality ofthe material is to 2 5 be maintained and the envelope is not to be opened, or the contents 2 6 revealed to any individual, except by order ofthe Court. 27 /// 2 /// 8 2460-1002/677067.1 Case No. 2:16-cv-08773-GW-E [ PROPOSED]STIPULATED PROTECTIVE ORDER 2:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 9 of 16 Page ID #:124 1 12) Acceptance of Information; Inadvertent Disclosure. Acceptance by a 2 ~ Party or its Attorney of Information disclosed under designation as protected shall 3 ~ not constitute an admission that the Information is, in fact, entitled to protection. 4 ~ Inadvertent disclosure of information which the disclosing Party intended to 5 ~ designate as protected shall not constitute waiver of any right to claim the Information 6 as protected upon discovery ofthe error. In the event a Party inadvertently files a 7 document containing protected Information, such party should immediately inform 8 the Court and take steps necessary to withdraw the document and resubmit a sealed or 9 a redacted, publicly available copy ofsuch document. 10 If, through inadvertence, a producing Party provides any "CONFIDENTIAL" 11 ~ or "CONFIDENTIAL -ATTORNEYS'EYES ONLY"discovery material without 12 marking the Information as "CONFIDENTIAL" or "CONFIDENTIAL 13 ATTORNEYS'EYES ONLY,"the producing Party may subsequently inform the 14 receiving Party in writing of the "CONFIDENTIAL" or "CONFIDENTIAL 15 ATTORNEYS'EYES ONLY" nature of the disclosed Information, and the 16 receiving Party shall treat the disclosed Information in accordance with this Order 17 after receipt of such written notice and make reasonable efforts to retrieve any such 18 material that has been disclosed to persons not authorized to receive the material under 19 the terms hereof. A Party objecting to any such "CONFIDENTIAL" or 20~ ~ "CONFIDENTIAL -ATTORNEYS'EYES ONLY" designation shall follow the 21 procedures set forth in paragraph 12 below. Prior disclosure of material later 22 designated as "CONFIDENTIAL" or "CONFIDENTIAL -ATTORNEYS' EYES 2 ONLY" shall not constitute a violation of this Order. 3 24 If a disclosing Party through inadvertence produces or provides discovery 2 material that it believes is subject to a claim of attorney-client privilege, work 5 2 product immunity, or any other privilege, the disclosing Party may give written notice 6 27 to the receiving Party that the discovery material is deemed privileged and that return 2 ofthe material is requested. Upon such written notice, the receiving Party shall 8 2460-1002 / 6770621 Case No. 2:16-cv-08773-GW-E [ PROPOSED]STIPULATED PROTECTIVE ORDER CaseI~:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 10 of 16 Page ID #:125 1 immediately gather the original and all copies of the material of which the 2 receiving Party is aware and shall immediately return the original and all such copies 3 to the disclosing Party. 4 13) Challenges to Designations of Information as Protected. If the Parties 5 or their Attorneys disagree as to whether certain information should be protected, 6 they are obligated to negotiate in good faith regarding the designation by the disclosing 7 Party. Ifthe Parties are unable to resolve their differences,the Party challenging the 8 designation may make a motion before the Court seeking a determination of the 9 status ofthe Information. 10 A challenge to the designation ofInformation as protected must be made 11 substantially contemporaneous with the designation, or as soon as practicable after 12 the basis for challenge is known. When a challenge is made long after a designation 13 ofInformation as protected,the challenging Party will be expected to show why it 14 could not have made the challenge at an earlier time. The Party designating 15 information as protected will, when its designation is timely challenged, bear the 16 ultimate burden ofproving that the Information should be protected. 17 14) Consequences of Unchallenged Overdesignations. In the event the 18 Court determines that a Party has improperly overdesignated information as protected, 19 and a Party has not contested the overdesignation, the Court, on its own initiative, 2 may: (1)disregard the overdesignation for those matters which are improperly 0 21 designated;(2)issue an order to show cause why the submission should not be made 22 open to public view;(3)require a Party to unseal or reduce redactions by 2 redesignating as non-confidential the overdesignated Information and resubmit a 3 24 public copy, a properly designated copy or a redacted copy for public view; or(4)not 25 consider the improperly designated matter in rendering its decision. In the case of an 2 order to show cause, or request for resubmission of a filing for public view or with 6 27 proper designation, if no response is received, the Court may redesignate the 2 /// 8 j~ za6o-ioozi6~~o6zi Case No. 2:16-cv-08773-GW-E [PROPOSED]STIPULATED PROTECTIVE ORDER Case ~~:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 11 of 16 Page ID #:126 1 confidentially filed material as CONFIDENTIAL or as non-confidential and make it 2 available for public view. 3 15) Court's Jurisdiction; Handling Materials After Termination. This 4 action is terminated only after a final order is entered and either all appellate 5 proceedings have been resolved or the time for filing an appeal has passed without iling of any appeal. 6 f 7 The Parties may agree that archival copies of evidence, memoranda, discovery 8 deposition transcripts, testimony deposition transcripts, affidavits, declarations, and 9 briefs may be retained solely by outside counsel, subject to compliance with agreed 10 safeguards. Otherwise, within 30 days after the final termination of this action, each 11 Party and their Attorneys, as well as any other persons subject to the terms of this 12 Order, shall return to each disclosing Party: (1)all materials and documents, 13 including ESI, containing protected Information;(2) all copies, summaries, and 14 abstracts thereof; and (3) all other materials, memoranda or documents embodying 15 data concerning said material, including all copies provided pursuant to paragraphs 4 16 and 5 ofthis Order. In the alternative, a Party or its Attorney may destroy such 17 materials rather than return them. Additionally, Parties to this agreement are 18 precluded from disclosing orally or in writing any protected Information provided 19 during the course of this action once this action is terminated. 2 0 16) Other Rights of the Parties and Attorneys. This Order shall not 21 preclude the Parties or their Attorneys from making any applicable claims of 22 privilege during discovery or at trial. Nor shall this Order preclude the filing of any 2 motion with the Court for relief from a particular provision of this Order or for 3 2 additional protections not provided by this Order. 4 25 IT IS SO STIPULATED,THROUGH COUNSEL OF RECORD. 2 6 [ SIGNATURES ON THE FOLLOWING PAGE] 27 2 8 il 2460-1002 /677067.1 Case No. 2:16-cv-08773-GW-E [ PROPOSED]STIPULATED PROTECTIVE ORDER Casel ~:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 12 of 16 Page ID #:127 1 Dated: Apri120, 2017 Respectfully submitted, 2 ZUBER LAWLER &DEL DUCA LLP DoN A.HERNANDEZ(SBN: 125119) 3 4 THE SEIGEL LAW FIRM LLC Maw L. SE1~EL(SBN: 634617) 5 6 7 BY ~ 8 /s/Don A. Hernandez Attorneys for Plaintiff ONLINE FLOWER SEARCH,LLC 9 10 Dated: April 20, 2017 Respectfully submitted, ll LAUSON & TARVER,LLP ROBERT J. LAusoN(SBN: 175486) 12 ~ 13 BY ~ 14 15 16 Dated: Apri120, 2017 17 /s/Robert J. Lauson Attorneys for Defendant FLORALSHIP, INC. Respectfully submitted, THE LAW OFFICE OF RICHARD R. RICE RICHARD R. R~cE(SBN: 159315) 18 19 2 0 BY~ 21 2 2 /s/Richard R. Rice Attorneys for Defendant CHARLES M. JACKSON 2 3 24 2 5 2 6 FOR GOOD CAUSE SHOWN,IT IS SO ORDERED. DATED: UNIT STATES MAGISTRATE JUDGE 2 7 2 8 ` zr:~an.~y~csrv:.rr~i 12 Case No. 2:16-cv-08773-GW-E [ PROPOSED]STIPULATED PROTECTIVE ORDER Case ~:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 13 of 16 Page ID #:128 1 Pursuant to Civil L.R. 5-4.3.4(a)(2)(i), the filer attests that all other 2 signatories listed, and on whose behalf this filing is submitted, concur in the filing's 3 content and have authorized the filing. 4 5 6 BY ~ /s/Don A. Hernandez 7 8 9 10 11 12 13 ! 14 15 16 17 18 19 2 0 21 22 2 3 24 2 5 2 6 27 2 8 2460-1002 /677067.1 Case No.2:16-cv-08773-GW-E [ PROPOSED]STIPULATED PROTECTIVE ORDER Case 2:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 14 of 16 Page ID #:129 EXHIBIT A Case x:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 15 of 16 Page ID #:130 1 2 EXHIBIT A: CERTIFICATE OF COMPLIANCE 3 Protected Information, in whole or in part, and the Information contained 4 therein which has been produced by the Parties in this action pursuant to the attached 5 Stipulated Protective Order has been disclosed to me,and by signing this Certificate 6 of Compliance, I acknowledge and agree that I have read, understand, and am subject 7 to the provisions ofthe Stipulated Protective Order and will not disclose such 8 protected Information in whole or in part or in any form or the Information contained 9 therein to any person, corporation, partnership, firm, governmental agency or 10 association other than those persons who are authorized under the Stipulated 11 Protective Order to have access to such information. 12 DATED: 13 (Signature) 14 15 Name (Print) 16 17 18 19 2 0 21 22 2 3 2 4 2 5 2 6 27 2 8 2460-]002/ 677067.1 Case No.2:16-cv-08773-GW-E [ PROPOSED]STIPULATED PROTECTIVE ORDER Case x:16-cv-08773-GW-E Document 29 Filed 04/20/17 Page 16 of 16 Page ID #:131 1 PROOF OF SERVICE 2 Online Flower Search v. Floralship Inc. et al. 2 :16-cv-08773-GW-E 3 STATE OF CALIFORNIA,COUNTY OF LOS ANGELES 4 At the time of service, I was over 18 years of a e and not a party to this action. 5 I am em toyed in the County of Los Angeles, State o~California. My business address s 777 S. Figueroa street, 37th Floor, Los Angeles, CA 90017. 6 On Apri120, 2017, I served true copies ofthe following documents)described 7 as rPROPOSED STIPULATED PROTECTIVE ORDER on the interested parties in this action as ~ollows: 8 Richard R. Rice, Esq. Attorneys for Defendant CHARLES M. JACKSON 9 Law Office of Richard R. Rice 1084 North El Camino Real, Suite B121 10 Encinitas, CA 92024 Telephone: 760)943-0100 11 Facsimile: (60~ 943-0942 E -Mail: rrrice( 12 Robert J. Lauson, Esq Attorneys for Defendant FLORALSHIP, 13 Lauson & Tarver LLP INC. 880 Apollo St., #302 14 El Segundo, CA 90245 Telephone: (310)726-0892 15 Facsunile: 310)726-0893 E -Mail: bo 16 BY CM/ECF NOTICE OF ELECTRONIC FILING: I electronically filed 17 the documents)with the Clerk ofthe Court by using the CM/ECF system. Participants in the case who are registered CM/ECF users will be served by the 18 CM/ECF system. Participants in the case who are not registered CM/ECF users will be served by mail or by other means permitted by the court rules. 19 I declare under penalty of perjury under the laws ofthe United States of 2 America that the foregoing is true and correct and that I am employed in the office of 0 a member ofthe bar of this Court at whose direction the service was made. 21 Executed on April 20, 2017, at Los Angeles, California. 22 2 3 / s/Alicia Navarro 24 Alicia Navarro 2 5 2 6 27 2 8 II za6oaoozi6~~o6zi Case No. 2:16-cv-08773-GW-E [PROPOSED]STIPULATED PROTECTIVE ORDER

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