Jesus Arteaga v. Walgreen Co. et al
Filing
22
PROTECTIVE ORDER by Magistrate Judge Steve Kim. In re: Stipulation for Protective Order 21 . (mkr)
1 BRYAN CAVE LLP
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3
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Leslie H. Helmer (SBN 150296)
Nicole N. King (SBN 290204)
120 Broadway, Suite 300
Santa Monica, California 90401-2386
Telephone: (310) 576-2100
Facsimile: (310) 576-2200
Email:
lhhelmer@bryancave.com
nicole.king@bryancave.com
7
Attorneys for Defendant
8 WALGREEN CO.
9
Santa Monica, CA 90301
Bryan Cave LLP
UNITED STATES DISTRICT COURT
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120 Broadway, Suite 300
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CENTRAL DISTRICT OF CALIFORNIA
12
13 JESUS ARTEAGA, an individual,
Case No. 2:17-cv-00130-JFW(SKx)
14
Plaintiff,
Honorable John F. Walter
vs.
STIPULATED PROTECTIVE
ORDER
15
16
WALGREEN CO., an Illinois
17 corporation; and DOES 1 through 50,
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19
inclusive,
Defendants.
Complaint Filed:
November 22, 2016
Removed to USDC: January 6, 2016
Trial Date:
December 19, 2017
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STIPULATED PROTECTIVE ORDER
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1 1.
A.
PURPOSES AND LIMITATIONS
2
Discovery in this action is likely to involve production of confidential,
3 proprietary, or private information for which special protection from public
4 disclosure and from use for any purpose other than prosecuting this litigation may
5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
6 enter the following Stipulated Protective Order. The parties acknowledge that this
7 Order does not confer blanket protections on all disclosures or responses to
8 discovery and that the protection it affords from public disclosure and use extends
9 only to the limited information or items that are entitled to confidential treatment
10 under the applicable legal principles. The parties further acknowledge, as set forth in
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11 Section 12.3, below, that this Stipulated Protective Order does not entitle them to
12 file confidential information under seal; Civil Local Rule 79-5 sets forth the
13 procedures that must be followed and the standards that will be applied when a party
14 seeks permission from the court to file material under seal.
15
B.
GOOD CAUSE STATEMENT
16
This action may involve the production of confidential information, including
17 information regarding other employees at Walgreens or other third parties for which
18 special protection from public disclosure and from use for any purpose other than
19 litigation of this action is warranted because the information implicates privacy rights
20 of third parties. Specifically, this action may involve the production of employee
21 personnel information for which special protection from public disclosure and from
22 use for any purpose other than litigation of this action is warranted because the
23 information implicates privacy rights of third parties. The action may also involve
24 other confidential and/or proprietary business information, including the production
25 of internal policies of Walgreens and Walgreens’ store procedures that are otherwise
26 generally unavailable to the public, or which may be privileged or otherwise protected
27 from disclosure under state or federal statutes, court rules, case decisions, or common
28 law. Accordingly, to expedite the flow of information, to facilitate the prompt
1
STIPULATED PROTECTIVE ORDER
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1 resolution of disputes over confidentiality of discovery materials, to adequately
2 protect information the parties are entitled to keep confidential, to ensure that the
3 parties are permitted reasonable necessary uses of such material in preparation for and
4 in the conduct of trial, to address their handling at the end of the litigation, and serve
5 the ends of justice, a protective order for such information is justified in this matter. It
6 is the intent of the parties that information will not be designated as confidential for
7 tactical reasons and that nothing be so designated without a good faith belief that it
8 has been maintained in a confidential, non-public manner, and there is good cause
9 why it should not be part of the public record of this case.
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DEFINITIONS
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Bryan Cave LLP
10 2.
2.1
Action: This pending federal law suit.
12
2.2
Challenging Party: a Party or Non-Party that challenges the designation
13 of information or items under this Order.
14
2.3
“CONFIDENTIAL” Information or Items: information (regardless of
15 how it is generated, stored or maintained) or tangible things that qualify for
16 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
17 the Good Cause Statement.
18
2.4
Counsel: Outside Counsel of Record and In-House Counsel (as well as
19 their support staff).
20
2.5
Designating Party: a Party or Non-Party that designates information or
21 items that it produces in disclosures or in responses to discovery as
22 “CONFIDENTIAL.”
23
2.6
Disclosure or Discovery Material: all items or information, regardless
24 of the medium or manner in which it is generated, stored, or maintained (including,
25 among other things, testimony, transcripts, and tangible things), that are produced or
26 generated in disclosures or responses to discovery in this matter.
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2
STIPULATED PROTECTIVE ORDER
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2.7
1
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
3 an expert witness or as a consultant in this Action.
2.8
4
In-House Counsel: Attorneys who are employees of a Party to this
5 Action. In-House Counsel does not include Outside Counsel of Record or any other
6 outside counsel.
2.9
7
Non-Party: any natural person, partnership, corporation, association, or
8 other legal entity not named as a Party to this action.
2.10 Outside Counsel of Record: Attorneys who are not employees of a
9
10 Party to this Action but are retained to represent or advise a Party to this Action and
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11 have appeared in this Action on behalf of that Party or are affiliated with a law firm
12 which has appeared on behalf of that Party, and includes support staff.
2.11 Party: any Party to this Action, including all of its officers, directors,
13
14 employees, consultants, retained experts, and Outside Counsel of Record (and their
15 support staffs).
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
16
17 Discovery Material in this Action.
2.13 Professional Vendors: persons or entities that provide litigation support
18
19 services (e.g., photocopying, videotaping, translating, preparing exhibits or
20 demonstrations, and organizing, storing, or retrieving data in any form or medium)
21 and their employees and subcontractors.
2.14 Protected Material: any Disclosure or Discovery Material that is
22
23 designated as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
24
25 from a Producing Party.
26 3.
SCOPE
27
The protections conferred by this Stipulation and Order cover not only
28 Protected Material (as defined above), but also (1) any information copied or
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STIPULATED PROTECTIVE ORDER
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1 extracted from Protected Material; (2) all copies, excerpts, summaries, or
2 compilations of Protected Material; and (3) any testimony, conversations, or
3 presentations by Parties or their Counsel that might reveal Protected Material.
Any use of Protected Material at trial shall be governed by the orders of the
4
5 trial judge. This Order does not govern the use of Protected Material at trial.
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
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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 5.
DESIGNATING PROTECTED MATERIAL
16
5.1
17
Each Party or Non-Party that designates information or items for protection
Exercise of Restraint and Care in Designating Material for Protection.
18 under this Order must take care to limit any such designation to specific material
19 that qualifies under the appropriate standards. The Designating Party must designate
20 for protection only those parts of material, documents, items, or oral or written
21 communications that qualify so that other portions of the material, documents,
22 items, or communications for which protection is not warranted are not swept
23 unjustifiably within the ambit of this Order.
24
Mass, indiscriminate, or routinized designations are prohibited. Designations
25 that are shown to be clearly unjustified or that have been made for an improper
26 purpose (e.g., to unnecessarily encumber the case development process or to impose
27 unnecessary expenses and burdens on other parties) may expose the Designating
28 Party to sanctions.
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1
If it comes to a Designating Party’s attention that information or items that it
2 designated for protection do not qualify for protection, that Designating Party must
3 promptly notify all other Parties that it is withdrawing the inapplicable designation.
4
5.2
Manner and Timing of Designations. Except as otherwise provided in
5 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
7 under this Order must be clearly so designated before the material is disclosed or
8 produced.
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10
Designation in conformity with this Order requires:
(a)
for information in documentary form (e.g., paper or electronic
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11 documents, but excluding transcripts of depositions or other pretrial or trial
12 proceedings), that the Producing Party affix at a minimum, the legend
13 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
14 contains protected material. If only a portion or portions of the material on a page
15 qualifies for protection, the Producing Party also must clearly identify the protected
16 portion(s) (e.g., by making appropriate markings in the margins).
17
A Party or Non-Party that makes original documents available for inspection
18 need not designate them for protection until after the inspecting Party has indicated
19 which documents it would like copied and produced. During the inspection and
20 before the designation, all of the material made available for inspection shall be
21 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
22 documents it wants copied and produced, the Producing Party must determine which
23 documents, or portions thereof, qualify for protection under this Order. Then, before
24 producing the specified documents, the Producing Party must affix the
25 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
26 portion or portions of the material on a page qualifies for protection, the Producing
27 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
28 markings in the margins).
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STIPULATED PROTECTIVE ORDER
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(b)
1
for testimony given in depositions that the Designating Party
2 identify the Disclosure or Discovery Material on the record, before the close of the
3 deposition all protected testimony.
(c)
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for information produced in some form other than documentary
5 and for any other tangible items, that the Producing Party affix in a prominent place
6 on the exterior of the container or containers in which the information is stored the
7 legend “CONFIDENTIAL.” If only a portion or portions of the information
8 warrants protection, the Producing Party, to the extent practicable, shall identify the
9 protected portion(s).
5.3
10
Inadvertent Failures to Designate. If timely corrected, an inadvertent
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11 failure to designate qualified information or items does not, standing alone, waive
12 the Designating Party’s right to secure protection under this Order for such material.
13 Upon timely correction of a designation, the Receiving Party must make reasonable
14 efforts to assure that the material is treated in accordance with the provisions of this
15 Order.
16 6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
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6.1
Timing of Challenges. Any Party or Non-Party may challenge a
18 designation of confidentiality at any time that is consistent with the Court’s
19 Scheduling Order.
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6.2
Meet and Confer. The Challenging Party shall initiate the
21 dispute resolution process under Local Rule 37.1 et seq.
22
6.3
The burden of persuasion in any such challenge proceeding shall be on
23 the Designating Party. Frivolous challenges, and those made for an improper
24 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
25 parties) may expose the Challenging Party to sanctions. Unless the Designating
26 Party has waived or withdrawn the confidentiality designation, all parties shall
27 continue to afford the material in question the level of protection to which it is
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STIPULATED PROTECTIVE ORDER
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1 entitled under the Producing Party’s designation until the Court rules on the
2 challenge.
3 7.
ACCESS TO AND USE OF PROTECTED MATERIAL
4
7.1
Basic Principles. A Receiving Party may use Protected Material that is
5 disclosed or produced by another Party or by a Non-Party in connection with this
6 Action only for prosecuting, defending, or attempting to settle this Action. Such
7 Protected Material may be disclosed only to the categories of persons and under the
8 conditions described in this Order. When the Action has been terminated, a
9 Receiving Party must comply with the provisions of section 13 below (FINAL
10 DISPOSITION).
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Protected Material must be stored and maintained by a Receiving Party at a
12 location and in a secure manner that ensures that access is limited to the persons
13 authorized under this Order.
14
7.2
Disclosure of “CONFIDENTIAL” Information or Items. Unless
15 otherwise ordered by the court or permitted in writing by the Designating Party, a
16 Receiving Party may disclose any information or item designated
17 “CONFIDENTIAL” only to:
18
(a)
the Receiving Party’s Outside Counsel of Record in this Action,
19 as well as employees of said Outside Counsel of Record to whom it is reasonably
20 necessary to disclose the information for this Action;
21
(b)
the officers, directors, and employees (including House Counsel)
22 of the Receiving Party to whom disclosure is reasonably necessary for this Action;
23
(c)
Experts (as defined in this Order) of the Receiving Party to
24 whom disclosure is reasonably necessary for this Action and who have signed the
25 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
26
(d)
the court and its personnel;
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(e)
court reporters and their staff;
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(f)
professional jury or trial consultants, mock jurors, and
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STIPULATED PROTECTIVE ORDER
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1 Professional Vendors to whom disclosure is reasonably necessary for this Action
2 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
3 A);
(g)
4
the author or recipient of a document containing the information
5 or a custodian or other person who otherwise possessed or knew the information;
(h)
6
during their depositions, witnesses, and attorneys for witnesses,
7 in the Action to whom disclosure is reasonably necessary provided: (1) the deposing
8 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
9 they will not be permitted to keep any confidential information unless they sign the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
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11 agreed by the Designating Party or ordered by the court. Pages of transcribed
12 deposition testimony or exhibits to depositions that reveal Protected Material may
13 be separately bound by the court reporter and may not be disclosed to anyone except
14 as permitted under this Stipulated Protective Order; and
(i)
15
any mediator or settlement officer, and their supporting
16 personnel, mutually agreed upon by any of the parties engaged in settlement
17 discussions.
18 8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
19
IN OTHER LITIGATION
20
If a Party is served with a subpoena or a court order issued in other litigation
21 that compels disclosure of any information or items designated in this Action as
22 “CONFIDENTIAL,” that Party must:
23
(a)
promptly notify in writing the Designating Party. Such
24 notification shall include a copy of the subpoena or court order;
25
(b)
promptly notify in writing the party who caused the subpoena or
26 order to issue in the other litigation that some or all of the material covered by the
27 subpoena or order is subject to this Protective Order. Such notification shall include
28 a copy of this Stipulated Protective Order; and
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STIPULATED PROTECTIVE ORDER
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(c)
1
cooperate with respect to all reasonable procedures sought to be
2 pursued by the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with
3
4 the subpoena or court order shall not produce any information designated in this
5 action as “CONFIDENTIAL” before a determination by the court from which the
6 subpoena or order issued, unless the Party has obtained the Designating Party’s
7 permission. The Designating Party shall bear the burden and expense of seeking
8 protection in that court of its confidential material and nothing in these provisions
9 should be construed as authorizing or encouraging a Receiving Party in this Action
10 to disobey a lawful directive from another court.
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11 9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
12
PRODUCED IN THIS LITIGATION
13
(a)
The terms of this Order are applicable to information produced
14 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
15 information produced by Non-Parties in connection with this litigation is protected
16 by the remedies and relief provided by this Order. Nothing in these provisions
17 should be construed as prohibiting a Non-Party from seeking additional protections.
18
(b)
In the event that a Party is required, by a valid discovery request,
19 to produce a Non-Party’s confidential information in its possession, and the Party is
20 subject to an agreement with the Non-Party not to produce the Non-Party’s
21 confidential information, then the Party shall:
(1)
22
promptly notify in writing the Requesting Party and the
23 Non-Party that some or all of the information requested is subject to a
24 confidentiality agreement with a Non-Party;
(2)
25
promptly provide the Non-Party with a copy of the
26 Stipulated Protective Order in this Action, the relevant discovery request(s), and a
27 reasonably specific description of the information requested; and
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(3)
1
make the information requested available for inspection by
2 the Non-Party, if requested.
(c)
3
If the Non-Party fails to seek a protective order from this court
4 within 14 days of receiving the notice and accompanying information, the Receiving
5 Party may produce the Non-Party’s confidential information responsive to the
6 discovery request. If the Non-Party timely seeks a protective order, the Receiving
7 Party shall not produce any information in its possession or control that is subject to
8 the confidentiality agreement with the Non-Party before a determination by the
9 court. Absent a court order to the contrary, the Non-Party shall bear the burden and
10 expense of seeking protection in this court of its Protected Material.
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11 10.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
12
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
13 Protected Material to any person or in any circumstance not authorized under this
14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
15 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
16 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
17 persons to whom unauthorized disclosures were made of all the terms of this Order,
18 and (d) request such person or persons to execute the “Acknowledgment and
19 Agreement to Be Bound” that is attached hereto as Exhibit A.
20 11.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
21
PROTECTED MATERIAL
22
When a Producing Party gives notice to Receiving Parties that certain
23 inadvertently produced material is subject to a claim of privilege or other protection,
24 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
25 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
26 may be established in an e-discovery order that provides for production without
27 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
28 as the parties reach an agreement on the effect of disclosure of a communication or
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STIPULATED PROTECTIVE ORDER
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1 information covered by the attorney-client privilege or work product protection, the
2 parties may incorporate their agreement in the stipulated protective order submitted
3 to the court.
4 12.
MISCELLANEOUS
5
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
6 person to seek its modification by the Court in the future.
12.2 Right to Assert Other Objections. By stipulating to the entry of this
7
8 Protective Order no Party waives any right it otherwise would have to object to
9 disclosing or producing any information or item on any ground not addressed in this
10 Stipulated Protective Order. Similarly, no Party waives any right to object on any
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11 ground to use in evidence of any of the material covered by this Protective Order.
12.3 Filing Protected Material. A Party that seeks to file under seal any
12
13 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
14 only be filed under seal pursuant to a court order authorizing the sealing of the
15 specific Protected Material at issue. If a Party’s request to file Protected Material
16 under seal is denied by the court, then the Receiving Party may file the information
17 in the public record unless otherwise instructed by the court.
18 13.
FINAL DISPOSITION
19
After the final disposition of this Action, as defined in paragraph 4, within 60
20 days of a written request by the Designating Party, each Receiving Party must return
21 all Protected Material to the Producing Party or destroy such material. As used in
22 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
23 summaries, and any other format reproducing or capturing any of the Protected
24 Material. Whether the Protected Material is returned or destroyed, the Receiving
25 Party must submit a written certification to the Producing Party (and, if not the same
26 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
27 (by category, where appropriate) all the Protected Material that was returned or
28 destroyed and (2) affirms that the Receiving Party has not retained any copies,
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1 abstracts, compilations, summaries or any other format reproducing or capturing any
2 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
3 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
4 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
5 reports, attorney work product, and consultant and expert work product, even if such
6 materials contain Protected Material. Any such archival copies that contain or
7 constitute Protected Material remain subject to this Protective Order as set forth in
8 Section 3 (DURATION).
9 14.
Any violation of this Order may be punished by any and all appropriate
10 measures including, without limitation, contempt proceedings and/or monetary
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11 sanctions.
12
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
13 DATED: May 1, 2017
14 /s/ Jay S. Rothman
Jay S. Rothman, Esq.
15 Attorneys for Plaintiff JESUS ARTEAGA
16
17
18
lawyers@jayrothmanlaw.com
DATED: May 1, 2017
/s/ Leslie H. Helmer
19 Leslie H. Helmer
Nicole N. King
20 Attorneys for Defendant WALGREEN CO.
lhhelmer@bryancave.com
21 nicole.king@bryancave.com
22
23 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
24
25 DATED: May 2, 2017
26
27 __________________________________
Honorable Steve Kim
28 United States Magistrate Judge
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
I, ________________ [print or type full name], of ________________ [print
or type full address], declare under penalty of perjury that I have read in its entirety
and understand the Stipulated Protective Order that was issued by the United States
District Court for the Central District of California on [date] in the case of Jesus
Arteaga vs. Walgreen Co., et al., Case No. 2:17-cv-00130-JFW-SKx. I agree to
comply with and to be bound by all the terms of this Stipulated Protective Order and
I understand and acknowledge that failure to so comply could expose me to sanctions
and punishment in the nature of contempt. I solemnly promise that I will not disclose
in any manner any information or item that is subject to this Stipulated Protective
Order to any person or entity except in strict compliance with the provisions of this
Order. I further agree to submit to the jurisdiction of the United States District
Court for the Central District of California for the purpose of enforcing the
terms of this Stipulated Protective Order, even if such enforcement proceedings
occur after termination of this action. I hereby appoint _______________ [print
or type full name] of ____________________ [print or type full address and
telephone number] as my California agent for service of process in connection with
this action or any proceedings related to enforcement of this Stipulated Protective
Order.
Date:________________________________
City and State where sworn and signed:___________________________
Printed Name:_________________________
Signature:_____________________________
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STIPULATED PROTECTIVE ORDER
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PROOF OF SERVICE
FRCIVP 5(B)
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I am employed in the County of Los Angeles, State of California. I am over
3 the age of 18 and not a party to the within action. My business address is 120
4 Broadway, Suite 300, Santa Monica, California 90401-2386.
5
On May 1, 2017, I served the foregoing document, described as
STIPULATED PROTECTIVE ORDER, on each interested party in this action, as
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follows:
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Jay S. Rothman, Esq.
Jay S. Rothman & Associates
21900 Burbank Boulevard
Suite 210
Woodland Hills, CA 91367
Attorneys for Plaintiff
Phone:
Fax:
E-mails:
818-986-7870
818-990-3019
lawyers@jayrothmanlaw.com
Santa Monica, CA 90301
Bryan Cave LLP
120 Broadway, Suite 300
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(VIA ELECTRONIC SERVICE) The document was served via The
United States District Court –Central District’s CM/ECF electronic transfer
system which generates a Notice of Electronic Filing (NEF) upon the parties, the
assigned Judge and any registered user in the case.
BY ELECTRONIC MAIL: I caused the above-referenced document to
be served to the addressee on the attached service list via electronic mail.
I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.
Executed on May 1, 2017, at Santa Monica, California.
19
/s/ Lourdes O. Gomez
20
Lourdes O. Gomez
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PROOF OF SERVICE
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