Consultica Software Services, Inc. v. Lootsie, Inc. et al

Filing 28

PROTECTIVE ORDER by Magistrate Judge Suzanne H. Segal re Stipulation for Protective Order 25 . (mr)

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1 2 3 4 5 6 7 IN THE UNITED STATES DISTRICT COURT 8 9 10 11 FOR THE CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION CONSULTICA SOFTWARE SERVICES, INC., a Canadian corporation, 12 MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 14 15 16 19 Assigned to the Hon. Suzanne H. Segal Plaintiff, Courtroom 590 v. STIPULATED PROTECTIVE ORDER LOOTSIE, INC., a Delaware corporation; and DOES 1 through 20, inclusive, JURY TRIAL DEMANDED Defendants. 17 18 Case No. 2:16-cv-08984-SS Complaint Filed: December 5, 2016 LOOTSIE, INC., a Delaware corporation, 20 Counter-Claimant, 21 22 23 24 25 v. CONSULTICA SOFTWARE SERVICES, INC., a Canadian corporation, and ROES 1 through 20, inclusive, Counter-Defendants. 26 27 28 1 STIPULATED PROTECTIVE ORDER 1 The Court having read the Stipulation for Protective Order of the parties, and good 2 cause appearing thereof, 3 4 IT IS ORDERED AS FOLLOWS: PROTECTIVE ORDER 5 1. A. PURPOSES AND LIMITATIONS 6 Disclosure and discovery activity in this action are likely to involve production of 7 confidential, proprietary, or information considered by the producing party as a trade 8 secret for which special protection from public disclosure and from use for any purpose 9 other than prosecuting this or related litigation would be warranted. Accordingly, the 10 parties hereby agree to enter the following Protective Order. The parties acknowledge 11 that this Protective Order does not confer blanket protections on all disclosures or 12 responses to discovery and that the protection it affords extends only to the limited MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 information or items that are entitled under the applicable legal principles to treatment as 14 confidential. The parties further acknowledge, as set forth in Section 9, below, that this 15 Protective Order creates no entitlement to file confidential information under seal; the 16 Central District of California Local Rule 79-5.1 sets forth the procedures that must be 17 followed and reflects the standards that will be applied when a party seeks permission 18 from the court to file material under seal. Nothing in this Order shall be construed as 19 authorizing a party to disobey a lawful subpoena issued in another action. 20 B. GOOD CAUSE STATEMENT 21 This action is likely to involve trade secrets and other valuable research, 22 development, commercial, technical and/or proprietary information for which special 23 protection from public disclosure and from use for any purpose other than prosecution of 24 this action is warranted. Such confidential and proprietary materials and information 25 consist of, among other things, confidential business information regarding confidential 26 business practices, or other confidential research, development, or commercial 27 information (including information implicating privacy rights of third parties), 28 information otherwise generally unavailable to the public, or which may be privilege or 2 STIPULATED PROTECTIVE ORDER 1 otherwise protected from disclosure under state or federal statutes, court rules, case 2 decisions, or common law. Accordingly, to expedite the flow of information, to facilitate 3 the prompt resolution of disputes over confidentiality of discovery materials, to 4 adequately protect information the parties are entitled to keep confidential, to ensure that 5 the parties are permitted reasonable necessary uses of such material in preparation for 6 and in the conduct of trial, to address their handling at the end of the litigation, and serve 7 the ends of justice, a protective order for such information is justified in this matter. It is 8 the intent of the parties that information will not be designated as confidential for tactical 9 reasons and that nothing be so designated without a good faith belief that it has been 10 maintained in a confidential non-public manner, and there is good cause why it should 11 not be part of the public record of this case. DEFINITIONS 13 2.1 MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 12 2. Action: this pending federal law suit entitled Consultica Software Services, 14 Inc. v. Lootsie, Inc., Case No. 2:16-cv-08984-SS. 15 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 16 information or items under this Order. 17 2.3 “Confidential” Information or Items: information (regardless of how 18 generated, stored, or maintained) or tangible things that contain non-public financial, 19 personal, or business information. 20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 21 support staff). 22 2.5 Designating Party: a Party or non-party that designates information or items 23 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 24 2.6 Disclosure or Discovery Material: all items or information, regardless of the 25 medium or manner in which it is generated, stored, or maintained (including, among other 26 things, testimony, transcripts, or tangible things) that are produced or generated in 27 disclosures or responses to discovery in this matter. 28 / / / 3 STIPULATED PROTECTIVE ORDER 1 2.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 3 expert witness or as a consultant in this Action. 4 2.8 House Counsel: attorneys who are employees of a party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside counsel. 6 2.9 Non-Party: any natural person, partnership, corporation, association, or 7 other legal entity not named as a Party to this action. 8 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 9 this Action but are retained to represent or advise a party to the Action and have appeared 10 in this Action on behalf of that party or affiliated with a law firm which has appeared on 11 behalf of that party, and includes support staff. 12 2.11 Party: any party to this Action, including all of its officers, directors, MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 employees, consultants, retained experts, and Outside Counsel of Record (and their 14 support staffs). 15 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 16 Discovery Material in this action. 17 2.13 Professional Vendors: persons or entities that provide litigation support 18 services (e.g., photocopying, videotaping, translating, preparing exhibits or 19 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 20 their employees and subcontractors. 21 2.14 Protected Material: any Disclosure or Discovery Material that is designated 22 as “CONFIDENTIAL.” 23 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 24 from a Producing Party. 25 3. SCOPE 26 The protections conferred by this Protective Order cover not only Protected 27 Material (as defined above), but also (1) any information copied or extracted from 28 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 4 STIPULATED PROTECTIVE ORDER 1 Material; and (3) any testimony, conversations, or presentations by Parties or their 2 Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the trial 4 judge. This Order does not govern the used of Protected Material at trial. 5 4. DURATION 6 Even after final disposition of this litigation, the confidentiality obligations 7 imposed by this Order shall remain in effect until a Designating Party agrees otherwise 8 in writing or a court order otherwise directs. Final disposition shall be deemed to be the 9 later of (1) dismissal of all claims and defenses in this Action, with or without prejudice; 10 and (2) final judgment herein after the completion and exhaustion of all appeals, 11 rehearings, remands, trials, or reviews of this Action, including the time limits for filing 12 any motions or applications for extension of time pursuant to applicable law. MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 5. DESIGNATING PROTECTED MATERIAL 14 5.1 Exercise of Restraint and Care in Designating Material for Protection. 15 Each Party or Non-Party that designates information or items for protection under 16 this Order must take care to limit any such designation to specific material that qualifies 17 under the appropriate standards. The Designating Party must designate for protection 18 only those parts of material, documents, items, or oral or written communications that 19 qualify so that other portions of the material, documents, items, or communications for 20 which protection is not warranted are not swept unjustifiably within the ambit of this 21 Order. 22 Mass, indiscriminate, or routinized designations are prohibited. Designations that 23 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 24 to unnecessarily encumber the case development process or to impose unnecessary 25 expenses and burdens on other parties) may expose the Designating Party to sanctions. 26 If it comes to a Designating Party’s attention that information or items that it 27 designation for protection do not qualify for protection, that Designating Party must 28 promptly notify all other Parties that it is withdrawing the inapplicable designation. 5 STIPULATED PROTECTIVE ORDER 1 5.2 Manner and Timing of Designations. Except as otherwise provided in this 2 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 3 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 4 must be clearly so designated before the material is disclosed or produced. 5 6 Designation in conformity with this Order requires: (a) For information in documentary form (e.g., paper or electronic 7 documents, but excluding transcripts of depositions or other pretrial or trial proceedings), 8 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 9 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 10 portion or portions of the material on a page qualifies for protection, the Producing Party 11 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 12 in the margins). A Party or Non-Party that makes original documents available for inspection MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 14 need not to designate them for protection until after the inspecting Party has indicated 15 which documents it would like copied and produced. During the inspection and before 16 the designation, all of the material made available for inspection shall be deemed 17 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 18 copied and produced, the Producing Party must determine which documents, or portions 19 thereof, qualify for protection under this Order. Then, before producing the specified 20 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 21 that contains Protected Material. If only a portion or portions of the materials on a page 22 qualifies for protection, the Producing Party also must clearly identify the protected 23 portion(s) (e.g., by making appropriate markings in the margins.) 24 (b) For testimony given in depositions that the Designating Party identify 25 the Disclosure or Discovery Material on the record, before the close of the deposition all 26 protected testimony. 27 (c) For information produced in some form other than documentary and 28 for any other tangible items, that the Producing Party affix in a prominent place on the 6 STIPULATED PROTECTIVE ORDER 1 exterior of the container or containers in which the information is stored the legend 2 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 3 the Producing Party, to the extent practicable, shall identify the protected portion(s). 4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 5 to designate qualified information or items does not, standing alone, waive the 6 Designating Party’s right to secure protection under this Order for such material. Upon 7 timely correction of a designation, the Receiving Party must make reasonable efforts to 8 assure that the material is treated in accordance with the provisions of this Order. 9 6. 10 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 11 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 12 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 process under Local Rule 37.1 et seq. 14 6.3 The burden of persuasion in any such challenge proceeding shall be on the 15 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 16 to harass or impose unnecessary expenses and burdens on other parties) may expose the 17 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 18 the confidentiality designation, all parties shall continue to afford the materials in 19 question the level of protection to which it is entitled under the Producing Party’s 20 designation until the Court rules on the challenge. 21 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that is 23 disclosed or produced by another Party or by a non-party in connection with this Action 24 only for prosecuting, defending, or attempting to settle this Action. Such Protected 25 Material may be disclosed only to the categories of persons and under the conditions 26 described in this Protective Order. When the Action has been terminated, a Receiving 27 Party must comply with the provisions of Section 13, below (FINAL DISPOSITION). 28 / / / 7 STIPULATED PROTECTIVE ORDER 1 Protected Material must be stored and maintained by a Receiving Party at a 2 location and in a secure manner that ensures that access is limited to the persons 3 authorized under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 5 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 6 may disclose any information or item designated “CONFIDENTIAL” only to: 7 (a) the Receiving Party’s Outside Counsel of record in this Action, as 8 well as employees of said Outside Counsel of Record to whom it is reasonably necessary 9 to disclose the information for this Action; 10 (b) the officers, directors, and employees (including House Counsel) of 11 the Receiving Party to whom disclosure is reasonably necessary for this Action; 12 (c) Experts (as defined in this Order) of the Receiving Party to whom MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 disclosure is reasonably necessary for this Action and who have signed the 14 “Acknowledgement and Agreement to Be Bound” (Exhibit A); 15 (d) the Court and its personnel; 16 (e) court reporters and their staff; 17 (f) professional jury or trial consultants, mock jurors, and Professional 18 Vendors to whom disclosure is reasonably necessary for this Action and who have signed 19 the “Acknowledgement and Agreement to Be Bound” (Exhibit A); 20 (g) the author or recipient of a document containing the information or a 21 custodian or other person who otherwise possessed or knew the information; 22 (h) during their depositions, witnesses, and attorneys for witnesses, in the 23 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 24 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not 25 be permitted to keep any confidential information unless they sign the 26 “Acknowledgement and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 27 by the Designating Party or ordered by the court. Pages of transcribed deposition 28 testimony or exhibits to depositions that reveal Protected Material may be separately 8 STIPULATED PROTECTIVE ORDER 1 bound by the court reporter and may not be disclosed to anyone except as permitted under 2 this Stipulated Protective Order; and 3 (i) any mediator or settlement officer, and their supporting personnel, 4 mutually agreed upon by any of the parties engaged in settlement discussions. 5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 6 OTHER LITIGATION. 7 If a Party is served with a subpoena or a court order issued in other litigation that 8 compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL,” that Party must: 10 (a) Promptly notify in writing the Designating Party. Such notification 11 shall include a copy of the subpoena or court order. 12 (b) Promptly notify in writing the party who caused the subpoena or order MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 to issue in the other litigation that some or all of the material covered by the subpoena or 14 order is subject to this Protective Order. Such notification shall include a copy of this 15 Stipulated Protective Order. 16 (c) Cooperate with respect to all reasonable procedures sought to be 17 pursued by the Designating Party whose Protected Material may be affected. 18 If the Designating Party timely seeks a protective order, the Party served with the 19 subpoena or court order shall not produce any information designated in this action as 20 “CONFIDENTIAL” before a determination by the court from which the subpoena or 21 order issued, uncles the Party has obtained the Designating Party’s permission. The 22 Designating Party shall bear the burden and expense of seeking protection in that court 23 of its confidential material and nothing in these provisions should be construed as 24 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 25 from another court. 26 / / / 27 / / / 28 / / / 9 STIPULATED PROTECTIVE ORDER 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 2 IN THIS LITIGATION. 3 (a) The terms of this Order are applicable to information produced by a Non-Party 4 in this Action and designated as “CONFIDENTIAL.” Such information produced by 5 Non-Parties in connection with this litigation is protected by the remedies and relief 6 provided by this Order. Nothing in these provisions should be construed as prohibiting a 7 Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to produce a 9 Non-Party’s confidential information in its possession, and the Party is subject to an 10 agreement with the Non-Party not to produce the Non-Party’s confidential information, 11 then the Party shall.: (1) promptly notify in writing the Requesting Party and the Non-Party that 12 MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 some or all of the information requested is subject to a confidentiality agreement with a 14 Non-Party; 15 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 16 Order in this Action, the relevant discovery request(s), and a reasonably specific 17 description of the information requested; and 18 (3) make the information requested available for inspection by the Non- 19 Party, if requested. 20 (c) If the Non-Party fails to seek a protective order from this court within 14 days 21 of receiving the notice and accompanying information, the Receiving Party may produce 22 the Non-Party’s confidential information responsive to the discovery request. If the Non23 Party timely seeks a protective order, the Receiving Party shall not produce any 24 information in its possession or control that is subject to the confidentiality agreement 25 with the Non-Party before a determination by the court. Absent a court order to the 26 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 27 court of its Protected Material. 28 / / / 10 STIPULATED PROTECTIVE ORDER 1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL. 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any persons or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 5 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 6 all unauthorized copies of the Protected Material, (c) inform the person or persons to 7 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 8 such person or persons to execute the “Acknowledgement and Agreement to Be Bound” 9 that is attached hereto as Exhibit A. 10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 11 PROTECTED MATERIAL 12 When a Producing Party gives notice to Receiving Parties that certain inadvertently MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 produced material is subject to a claim of privilege or other protection, the obligations of 14 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 15 This provision is not intended to modify whatever procedure may be established in an e16 discovery order that provides for production without prior privilege review. Pursuant to 17 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 18 effect of disclosure of a communication or information covered by the attorney-client 19 privilege or work product protection, the parties may incorporate their agreement in the 20 stipulated protective order submitted to the court. 21 12. MISCELLANEOUS 22 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 23 person to seek its modification by the Court in the future. 24 12.2 Right to Assert Other Objections. By stipulating to the entry of this 25 Protective Order no Party waives any right it otherwise would have to object to disclosing 26 or producing any information or item on any ground not addressed in this Stipulated 27 Protective Order. Similarly, no Party waives any right to object on any ground to use in 28 evidence of any material covered by this Protective Order. 11 STIPULATED PROTECTIVE ORDER 1 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 2 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 3 under seal pursuant to a court order authorizing the sealing of the specific Protected 4 Material at issue. If a Party’s request to file Protected Material under seal is denied by 5 the court, then the Receiving Party may file the information in the public record unless 6 otherwise instructed by the court. 7 13. FINAL DISPOSITION 8 After the final disposition of this Action, as defined in paragraph 4, within 60 days 9 of a written request by the Designating Party, each Receiving Party must return all 10 Protected Material to the Producing Party or destroy such material. As used in this 11 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 12 summaries, and any other format reproducing or capturing any of the Protected Material. MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 Whether the Protected Material is returned or destroyed, the Receiving Party must submit 14 a written certification to the Producing Party (and, if not the same person or entity, to the 15 Designating Party) by the 60 day deadline that (1) identifies (by category, where 16 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 17 the Receiving Party has not retained any copies, abstracts, compilations, summaries or 18 other format reproducing or capturing any of the Protected Material. Notwithstanding 19 this provision, Counsel are entitled to retain an archival copy of all pleadings, motion 20 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 21 deposition and trial exhibits, expert reports, attorney work product, and consultant and 22 expert work product, even if such materials contain Protected Material. Any such archival 23 copies that contain or constitute Protected Material remain subject to this Protective 24 Order as set forth in Section 4 (DURATION). 25 / / / 26 / / / 27 / / / 28 / / / 12 STIPULATED PROTECTIVE ORDER 1 14. Any violation of this Order may be punished by any and all appropriate measures 2 including, without limitation, contempt proceedings and/or monetary sanctions. 3 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 DATED: May 16, 2017 7 /s/Timothy A. Schneider Attorneys for Plaintiff and 9 Counterdefendant 10 Consultica Software Services, Inc. 8 11 12 DATED: May 16, 2017 MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 14 /s/Ashley M. Conlogue Attorneys for Defendant and Counterclaimant 16 Lootsie, Inc. 15 17 18 19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 20 21 DATED: 5/16/17 22 23 ___________/S/__________________ 24 Honorable Judge Suzanne H. Segal 25 26 27 28 13 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________________ [print or type full name], of 4 _____________________________________ [print or type full address], declare under 5 penalty of perjury that I have read in its entirety and understand the Stipulated Protective 6 Order that was issued by the District Court for the Central District of California on [date] 7 in the case of Consultica Software Services, Inc. v. Lootsie, Inc., Case No. 2:16-cv-089848 SS. I agree to comply with and to be bound by all the terms of this Stipulated Protective 9 Order and I understand and acknowledge that failure to so comply could expose me to 10 sanctions and punishment in the nature of contempt. I solemnly promise that I will not 11 disclose in any manner any information or item that is subject to this Stipulated Protective 12 Order to any person or entity except in strict compliance with the provisions of this Order. MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 I further agree to submit to the jurisdiction of the United States District Court for the 14 Central District of California for the purpose of enforcing the terms of this Stipulated 15 Protective Order, even if such enforcement proceedings occur after termination of this 16 action. I hereby appoint ___________________________ [print or type full name] of 17 ______________________________________________________________________ 18 [print or type full address and telephone number] as my California agent for service of 19 process in connection with this action or any proceedings related to enforcement of this 20 Stipulated Protective Order. 21 Date: __________________________________ 22 City and State where sworn and signed: __________________________________ 23 24 Printed name: __________________________________ 25 26 Signature: _____________________________________ 27 28 14 STIPULATED PROTECTIVE ORDER 1 2 Central District of California Case No. 2:16-cv-08984-SS Service of the attached document was accomplished pursuant to Central District of 3 California, Order Authorizing Electronic Filing, General Order No. 08-03 and Local Rule 4 5.3-3, which provide in part: “Upon the electronic filing of a document, a Notice of 5 Electronic Filing (NEF) is automatically generated by the CM/ECF system and sent by 6 e-mail to all attorneys in the case who are registered as CM/ECF Users and have 7 consented to electronic service. Service by this electronic NEF constitutes service 8 pursuant to the Federal Rules of Civil and Criminal Procedure for all attorneys who have 9 consented to electronic service.” 10 I declare under penalty of perjury under the laws of the United States of America 11 that the above is true and correct. 12 Executed on April 27, 2017, at Irvine, California. MYERS BERSTEIN LLP 4 EXECUTIVE CIRCLE, SUITE 100 IRVINE, CALIFORNIA 92614 13 14 By: /s/ Timothy A. Schneider Timothy A. Schneider 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15 STIPULATED PROTECTIVE ORDER

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