Nightcap Clothing, Inc. v. For Love And Lemons, LLC et al

Filing 22

PROTECTIVE ORDER by Magistrate Judge Steve Kim. In re: Stipulation for Protective Order 21 (mkr)

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1 STEVE K. WASSERMAN, ESQ. (Bar No. 58573) 2 3 4 5 6 skw@wassermanlawgroup.com KATHRYN S. MARSHALL, ESQ. (Bar No. 175081) ksm@wassermanlawgroup.com WASSERMAN LAW GROUP 5567 Reseda Boulevard, Suite 330 Tarzana, California 91356 Telephone: (818) 705-6800 Facsimile: (818) 705-8926 7 8 Attorneys for NIGHTCAP CLOTHING, INC. 9 UNITED STATES DISTRICT COURT 10 11 CENTRAL DISTRICT OF CALIFORNIA NIGHTCAP CLOTHING, INC. CASE NO. 2:16-cv-09310-CAS-SK (Assigned to Hon. Christina A. Snyder, Ctrm. 8D) 12 Plaintiff, 13 14 15 vs. [PROPOSED] ORDER TO STIPULATED PROTECTIVE ORDER FOR LOVE & LEMONS, LLC AND 16 DOES 1 to 10, 17 (Filed concurrently with Stipulated Protective Order) Defendant. 18 Complaint Filed: December 16, 2016 19 20 21 Having considered the parties' pleadings on file to date, and the parties' jointly 22 submitted Stipulated Protective Order to govern the handling of information and 23 materials produced in the course of discovery or filed with the Court in this action, 24 the Court determines as follows: 25 26 27 1. A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, 28 proprietary, or private information for which special protection from public 1 1 disclosure and from use for any purpose other than prosecuting this litigation may 2 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 3 enter the following Stipulated Protective Order. The parties acknowledge that this 4 Order does not confer blanket protections on all disclosures or responses to 5 discovery and that the protection it affords from public disclosure and use extends 6 only to the limited information or items that are entitled to confidential treatment 7 under the applicable legal principles. The parties further acknowledge, as set forth in 8 Section 12.3, below, that this Stipulated Protective Order does not entitle them to 9 file confidential information under seal; Civil Local Rule 79-5 sets forth the 10 procedures that must be followed and the standards that will be applied when a party 11 seeks permission from the court to file material under seal. 12 13 14 B. GOOD CAUSE STATEMENT This action is likely to involve trade secrets, customer, pricing, sales, profit 15 and revenue information, and other valuable research, development, commercial, 16 financial, technical and/or proprietary information for which special protection from 17 public disclosure and from use for any purpose other than prosecution of this action 18 is warranted. Such confidential and proprietary materials and information consist of, 19 among other things, confidential business or financial information, information 20 regarding confidential business practices, or other confidential research, 21 development, or commercial information (including information implicating privacy 22 rights of third parties), information otherwise generally unavailable to the public, or 23 which may be privileged or otherwise protected from disclosure under state or 24 federal statutes, court rules, case decisions, or common law. Accordingly, to 25 expedite the flow of information, to facilitate the prompt resolution of disputes over 26 confidentiality of discovery materials, to adequately protect information the parties 27 are entitled to keep confidential, to ensure that the parties are permitted reasonable 28 necessary uses of such material in preparation for and in the conduct of trial, to 2 1 address their handling at the end of the litigation, and serve the ends of justice, a 2 protective order for such information is justified in this matter. It is the intent of the 3 parties that information will not be designated as confidential for tactical reasons 4 and that nothing be so designated without a good faith belief that it has been 5 maintained in a confidential, non-public manner, and there is good cause why it 6 should not be part of the public record of this case. 7 8 2. DEFINITIONS 9 2.1 Action: this pending federal law suit 10 2.2 Challenging Party: a Party or Non-Party that challenges the designation 11 of information or items under this Order. 12 2.3 "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL – ATTORNEYS' 13 EYES ONLY" Information or Items: information (regardless of how it is generated, 14 stored or maintained) or tangible things that qualify for protection under Federal 15 Rule of Civil Procedure 26(c), and as specified above in the Good Cause Statement. 16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 17 their support staff). 18 2.5 Designating Party: a Party or Non-Party that designates information or 19 items that it produces in disclosures or in responses to discovery as 20 "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL- ATTORNEYS' EYES 21 ONLY." 22 2.6 Disclosure or Discovery Material: all items or information, regardless 23 of the medium or manner in which it is generated, stored, or maintained (including, 24 among other things, testimony, transcripts, and tangible things), that are produced or 25 generated in disclosures or responses to discovery in this matter. 26 2.7 Expert: a person with specialized knowledge or experience in a matter 27 pertinent to the litigation who has been retained by a Party or its counsel to serve as 28 an expert witness or as a consultant in this Action. 3 1 2.8 House Counsel: attorneys who are employees of a party to this Action. 2 House Counsel does not include Outside Counsel of Record or any other outside 3 counsel. 4 2.9 Non-Party: any natural person, partnership, corporation, association, or 5 other legal entity not named as a Party to this action. 6 2.10 Outside Counsel of Record: attorneys who are not employees of a party 7 to this Action but are retained to represent or advise a party to this Action and have 8 appeared in this Action on behalf of that party or are affiliated with a law firm which 9 has appeared on behalf of that party, and includes support staff. 10 2.11 Party: any party to this Action, including all of its officers, directors, 11 employees, consultants, retained experts, and Outside Counsel of Record (and their 12 support staffs). 13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 14 Discovery Material in this Action. 15 2.13 Professional Vendors: persons or entities that provide litigation support 16 services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) 18 and their employees and subcontractors. 19 2.14 Protected Material: any Disclosure or Discovery Material that is 20 designated as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL – 21 ATTORNEYS' EYES ONLY." 22 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 23 from a Producing Party. 24 25 3. SCOPE 26 The protections conferred by this Stipulation and Order cover not only 27 Protected Material (as defined above), but also (1) any information copied or 28 extracted from Protected Material; (2) all copies, excerpts, summaries, or 4 1 compilations of Protected Material; and (3) any testimony, conversations, or 2 presentations by Parties or their Counsel that might reveal Protected Material. Any 3 use of Protected Material at trial shall be governed by the orders of the trial judge. 4 This Order does not govern the use of Protected Material at trial. 5 6 4. DURATION 7 Even after final disposition of this litigation, the confidentiality obligations 8 imposed by this Order shall remain in effect until a Designating Party agrees 9 otherwise in writing or a court order otherwise directs. Final disposition shall be 10 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 11 or without prejudice; and (2) final judgment herein after the completion and 12 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 13 including the time limits for filing any motions or applications for extension of time 14 pursuant to applicable law. 15 16 5. DESIGNATING PROTECTED MATERIAL 17 5.1 Exercise of Restraint and Care in Designating Material for Protection. 18 Each Party or Non-Party that designates information or items for protection under 19 this Order must take care to limit any such designation to specific material that 20 qualifies under the appropriate standards. The Designating Party must designate for 21 protection only those parts of material, documents, items, or oral or written 22 communications that qualify so that other portions of the material, documents, 23 items, or communications for which protection is not warranted are not swept 24 unjustifiably within the ambit of this Order. 25 Mass, indiscriminate, or routinized designations are prohibited. Designations 26 that are shown to be clearly unjustified or that have been made for an improper 27 purpose (e.g., to unnecessarily encumber the case development process or to impose 28 unnecessary expenses and burdens on other parties) may expose the Designating 5 1 Party to sanctions. 2 If it comes to a Designating Party's attention that information or items that it 3 designated for protection do not qualify for protection, that Designating Party must 4 promptly notify all other Parties that it is withdrawing the inapplicable designation. 5 5.2 Manner and Timing of Designations. Except as otherwise provided in 6 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 7 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 8 under this Order must be clearly so designated before the material is disclosed or 9 produced. 10 11 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 12 documents, but excluding transcripts of depositions or other pretrial or trial 13 proceedings), that the Producing Party affix at a minimum, the legend 14 "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL – ATTORNEYS' EYES 15 ONLY" (hereinafter "CONFIDENTIAL legend"), to each page that contains 16 protected material. If only a portion or portions of the material on a page 17 qualifies for protection, the Producing Party also must clearly identify the protected 18 portion(s ) (e.g., by making appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and 22 before the designation, all of the material made available for inspection shall be 23 deemed "CONFIDENTIAL." After the inspecting Party has identified the 24 documents it wants copied and produced, the Producing Party must determine which 25 documents, or portions thereof, qualify for protection under this Order. Then, before 26 producing the specified documents, the Producing Party must affix the 27 "CONFIDENTIAL legend" to each page that contains Protected Material. If only a 28 portion or portions of the material on a page qualifies for protection, the Producing 6 1 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 2 markings in the margins). 3 (b) for testimony given in depositions that the designating Party 4 identify the Disclosure or Discovery Material on the record, before the close of the 5 deposition all protected testimony. 6 (c) for information produced in some form other than documentary 7 and for any other tangible items, that the producing Party affix in a prominent place 8 on the exterior of the container or containers in which the information is stored the 9 legend "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL – ATTORNEYS' 10 EYES ONLY." If only a portion or portions of the information warrants protection, 11 the Producing Party, to the extent practicable, shall identify the protected portion(s). 12 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 13 failure to designate qualified information or items does not, standing alone, waive 14 the Designating Party's right to secure protection under this Order for such material. 15 Upon timely correction of a designation, the Receiving Party must make reasonable 16 efforts to assure that the material is treated in accordance with the provisions of this 17 Order. 18 19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 21 designation of confidentiality at any time that is consistent with the Court's 22 Scheduling Order. 23 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 24 resolution process under Local Rule 37.1 et seq. 25 6.3 The burden of persuasion in any such challenge proceeding shall be on 26 the Designating Party. Frivolous challenges, and those made for an improper 27 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 28 parties) may expose the Challenging Party to sanctions. Unless the Designating. 7 1 Party has waived or withdrawn the confidentiality designation, all parties shall 2 continue to afford the material in question the level of protection to which it is 3 entitled under the Producing Party's designation until the Court rules on the 4 challenge. 5 7. ACCESS TO AND USE OF PROTECTED MATERIAL 6 7.1 Basic Principles. A Receiving Party may use Protected Material that is 7 disclosed or produced by another Party or by a Non-Party in connection with this 8 Action only for prosecuting, defending, or attempting to settle this Action. Such 9 Protected Material may be disclosed only to the categories of persons and under the 10 conditions described in this Order. When the Action has been terminated, a 11 Receiving Party must comply with the provisions of section 13 below (FINAL 12 DISPOSITION). 13 Protected Material must be stored and maintained by a Receiving Party at a 14 location and in a secure manner that ensures that access is limited to the persons 15 authorized under this Order. 16 7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless 17 otherwise ordered by the court or permitted in writing by the Designating Party, a 18 Receiving Party may disclose any information or item designated 19 "CONFIDENTIAL" only to: 20 (a) the Receiving Party's Outside Counsel of Record in this Action, 21 as well as employees of said Outside Counsel of Record to whom it is reasonably 22 necessary to disclose the information for this Action; 23 (b) the officers, directors, and employees (including House Counsel) 24 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 25 (c) Experts (as defined in this Order) of the Receiving Party to 26 whom disclosure is reasonably necessary for this Action and who have signed the 27 "Acknowledgment and Agreement to Be Bound" (Exhibit A); 28 (d) the court and its personnel; 8 1 (e) court reporters and their staff; 2 (f) professional jury or trial consultants, mock jurors, and 3 Professional Vendors to whom disclosure is reasonably necessary for this Action 4 and who have signed the "Acknowledgment and Agreement to Be Bound" (Exhibit 5 A); 6 (g) the author or recipient of a document containing the information 7 or a custodian or other person who otherwise possessed or knew the information; 8 (h) during their depositions, witnesses ,and attorneys for witnesses, 9 in the Action to whom disclosure is reasonably necessary provided: (1) the deposing 10 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 11 they will not be permitted to keep any confidential information unless they sign the 12 "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise 13 agreed by the Designating Party or ordered by the court. Pages of transcribed 14 deposition testimony or exhibits to depositions that reveal Protected Material may 15 be separately bound by the court reporter and may not be disclosed to anyone except 16 as permitted under this Stipulated Protective Order; and 17 (i) any mediator or settlement officer, and their supporting 18 personnel, mutually agreed upon by any of the parties engaged in settlement 19 discussions. 20 7.3 Materials Designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ 21 EYES ONLY”: Subject to the limitations in this Protective Order, Designated 22 Materials may be marked “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 23 ONLY” for the purpose of preventing the disclosure of information or materials 24 which, if disclosed to the receiving party, might cause competitive harm to the 25 Designating Party. Information and material that may be subject to this protection 26 includes, but is not limited to, technical and/or research and development data, 27 intellectual property, financial, marketing, and other sales data, and/or information 28 having strategic commercial value pertaining to the Designating Party’s trade or 9 1 business. Before designating any specific information “HIGHLY CONFIDENTIAL 2 – ATTORNEYS’ EYES ONLY,” the Designating Party’s counsel shall make a good 3 faith determination that the information warrants such protection. Materials 4 designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” materials 5 may be disclosed only to the following Designees: 6 (a) the Receiving Party's Outside Counsel of Record in this Action, 7 as well as employees of said Outside Counsel of Record to whom it is reasonably 8 necessary to disclose the information for this Action; 9 (b) Experts (as defined in this Order) of the Receiving Party to 10 whom disclosure is reasonably necessary for this Action and who have signed the 11 "Acknowledgment and Agreement to Be Bound" (Exhibit A); 12 (c) the court and its personnel; 13 (d) court reporters and their staff; 14 (e) professional jury or trial consultants, mock jurors, and 15 Professional Vendors to whom disclosure is reasonably necessary for this Action 16 and who have signed the "Acknowledgment and Agreement to Be Bound" (Exhibit 17 A); 18 (f) the author or recipient of a document containing the information 19 or a custodian or other person who otherwise possessed or knew the information; 20 (g) any mediator or settlement officer, and their supporting 21 personnel, mutually agreed upon by any of the parties engaged in settlement 22 discussions. 23 A Party (or only a Party’s principal or owner if a Party is a corporation or 24 other business entity) may be provided the ultimate or total figures, not detailed or 25 line item information, for the other Party’s revenues, sales and profit information, 26 notwithstanding any Party’s designation of documents showing such figures as 27 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” 28 10 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL – ATTORNEYS' EYES 6 ONLY," that Party must: 7 (a) promptly notify in writing the Designating Party. Such 8 notification shall include a copy of the subpoena or court order; 9 (b) promptly notify in writing the party who caused the subpoena or 10 order to issue in the other litigation that some or all of the material covered by the 11 subpoena or order is subject to this Protective Order. Such notification shall include 12 a copy of this Stipulated Protective Order; and 13 (c) cooperate with respect to all reasonable procedures sought to be 14 pursued by the Designating Party whose Protected Material may be affected. 15 If the Designating Party timely seeks a protective order, the Party served with 16 the subpoena or court order shall not produce any information designated in this 17 action as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL – ATTORNEYS' 18 EYES ONLY" before a determination by the court from which the 19 subpoena or order issued, unless the Party has obtained the Designating Party's 20 permission. The Designating Party shall bear the burden and expense of seeking 21 protection in that court of its confidential material and nothing in these provisions 22 should be construed as authorizing or encouraging a Receiving Party in this Action 23 to disobey a lawful directive from another court. 24 25 9. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 26 PRODUCED IN THIS LITIGATION 27 (a) The terms of this Order are applicable to information produced 28 by a Non-Party in this Action and designated as "CONFIDENTIAL." Such 11 1 information produced by Non-Parties in connection with this litigation is protected 2 by the remedies and relief provided by this Order. Nothing in these provisions 3 should be construed as prohibiting a Non-Party from seeking additional protections. 4 (b) In the event that a Party is required, by a valid discovery request, 5 to produce a Non-Party's confidential information in its possession, and the Party is 6 subject to an agreement with the Non-Party not to produce the Non-Party's 7 confidential information, then the Party shall: 8 (1) promptly notify in writing the Requesting Party and the Non-Party 9 that some or all of the information requested is subject to a confidentiality 10 agreement with a Non-Party; 11 (2) promptly provide the Non-Party with a copy of the Stipulated 12 Protective Order in this Action, the relevant discovery request(s), and a reasonably 13 specific description of the information requested; and 14 (3) make the information requested available for inspection by the 15 Non-Party, if requested. 16 (c) If the Non-Party fails to seek a protective order from this court within 17 14 days of receiving the notice and accompanying information, the Receiving Party 18 may produce the Non-Party's confidential information responsive to the discovery 19 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 20 not produce any information in its possession or control that is subject to the 21 confidentiality agreement with the Non-Party before a determination by the court. 22 Absent a court order to the contrary, the Non-Party shall bear the burden and 23 expense of seeking protection in this court of its Protected Material. 24 25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 27 Protected Material to any person or in any circumstance not authorized under this 28 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 12 1 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 2 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 3 persons to whom unauthorized disclosures were made of all the terms of this Order, 4 and (d) request such person or persons to execute the "Acknowledgment and 5 Agreement to Be Bound" that is attached hereto as Exhibit A. 6 7 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 8 OTHERWISE PROTECTED MATERIAL 9 When a Producing Party gives notice to Receiving Parties that certain 10 inadvertently produced material is subject to a claim of privilege or other protection, 11 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 12 Procedure 26(b )(5)(B). This provision is not intended to modify whatever 13 procedure may be established in an e-discovery order that provides for production 14 without prior privilege review. Pursuant to Federal Rule of Evidence 502( d) and ( 15 e), insofar as the parties reach an agreement on the effect of disclosure of a 16 communication or information covered by the attorney-client privilege or work 17 product protection, the parties may incorporate their agreement in the stipulated 18 protective order submitted to the court. 19 20 12. MISCELLANEOUS 21 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 22 person to seek its modification by the Court in the future. 23 12.2 Right to Assert Other Objections. By stipulating to the entry of this 24 Protective Order no Party waives any right it otherwise would have to object to 25 disclosing or producing any information or item on any ground not addressed in this 26 Stipulated Protective Order. Similarly, no Party waives any right to object on any 27 ground to use in evidence of any of the material covered by this Protective Order. 28 12.3 Filing Protected Material. A Party that seeks to file under seal any 13 1 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 2 only be filed under seal pursuant to a court order authorizing the sealing of the 3 specific Protected Material at issue. If a Party's request to file Protected Material 4 under seal is denied by the court, then the Receiving Party may file the information 5 in the public record unless otherwise instructed by the court. 6 7 l3. FINAL DISPOSITION 8 After the final disposition of this Action, as defined in paragraph 4, within 60 9 days of a written request by the Designating Party, each Receiving Party must return 10 all Protected Material to the Producing Party or destroy such material. As used in 11 this subdivision, "all Protected Material" includes all copies, abstracts, compilations, 12 summaries, and any other format reproducing or capturing any of the Protected 13 Material. Whether the Protected Material is returned or destroyed, the Receiving 14 Party must submit a written certification to the Producing Party (and, if not the same 15 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 16 (by category, where appropriate) all the Protected Material that was returned or 17 destroyed and (2)affirms that the Receiving Party has not retained any copies, 18 abstracts, compilations, summaries or any other format reproducing or capturing any 19 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 20 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 21 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 22 reports, attorney work product, and consultant and expert work product, even if such 23 materials contain Protected Material. Any such archival copies that contain or 24 constitute Protected Material remain subject to this Protective Order as set forth in 25 Section 4 (DURATION). 26 \\ 27 \\ 28 \\ 14 1 14. Any violation of this Order may be punished by any and all appropriate 2 measures including, without limitation, contempt proceedings and/or monetary 3 sanctions. 4 5 IT IS SO ORDERED. 6 7 DATED: July 3, 2017 8 9 Honorable Steve Kim United States Magistrate Judge 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15 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 6 penalty of perjury that I have read in its entirety and understand the Stipulated 7 Protective Order that was issued by the United States District Court for the Central 8 District of California on [date] in the case of Nightcap Clothing, Inc. 9 v. For Love & Lemons, LLC, Case No. 2:16-cv-09310-CAS-SK. I agree to comply 10 with and to be bound by all the terms of this Stipulated Protective Order and I 11 understand and acknowledge that failure to so comply could expose me to sanctions 12 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 15 provisions of this Order. I further agree to submit to the jurisdiction of the United 16 States District Court for the Central District of California for the purpose of 17 enforcing the terms of this Stipulated Protective Order, even if such enforcement 18 proceedings occur after termination of this action. I hereby appoint 19 [print or type full name] of 20 [print or type full address and 21 telephone number] as my California agent for service of process in connection with 22 this action or any proceedings related to enforcement of this Stipulated Protective 23 Order. 24 Date: ________________ 25 City and State where sworn and signed: 26 Printed name: 27 28 Signature: 16 1 CERTIFICATION OF SERVICE 2 3 I hereby certify that on June 30, 2017, I electronically filed the 4 [PROPOSED] ORDER TO STIPULATED PROTECTIVE ORDER with the 5 Clerk of the Court by using the CM/ECF system. 6 7 DATED: June 30, 2017 8 WASSERMAN LAW GROUP STEVE K. WASSERMAN, ESQ. KATHRYN S. MARSHALL, ESQ. 9 10 11 By: /s/ Kathryn S. Marshall KATHRYN S. MARSHALL Attorneys for NIGHTCAP CLOTHING, INC. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 17

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