Thunder Studios, Inc. v. Charif Kazal et al
Filing
125
STIPULATED PROTECTIVE ORDER by Magistrate Judge Suzanne H. Segal re APPLICATION for Protective Order 124 . (see order for details) (hr)
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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2:17-cv-00871 AB (SSx)
THUNDER STUDIOS, INC.;
RODRIC DAVID,
Plaintiffs,
v.
STIPULATED PROTECTIVE
ORDER
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CHARIF KAZAL; TONY KAZAL;
ADAM KAZAL; AND DOES 1 TO
100, INCLUSIVE,
Defendants.
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1.
A. PURPOSES AND LIMITATIONS
Discovery in this action is likely to involve production of confidential,
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proprietary, or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may
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be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
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enter the following Stipulated Protective Order. The parties acknowledge that this
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Order does not confer blanket protections on all disclosures or responses to
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discovery and that the protection it affords from public disclosure and use extends
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only to the limited information or items that are entitled to confidential treatment
under the applicable legal principles. The parties further acknowledge, as set forth in
Section 12.3, below, that this Stipulated Protective Order does not entitle them to
file confidential information under seal; Civil Local Rule 79-5 sets forth the
procedures that must be followed and the standards that will be applied when a party
seeks permission from the court to file material under seal in this Court.
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B. GOOD CAUSE STATEMENT
This action is likely to involve the production of private records of a sensitive
nature, as well as other documents and information protected by the right to privacy,
containing information generally unavailable to the public, for which special
protection from public disclosure and from use for any purpose other than
prosecution of this action is warranted. Accordingly, to expedite the flow of
information, to facilitate the prompt resolution of disputes over confidentiality of
discovery materials, to adequately protect information the parties are entitled to keep
confidential, to ensure that the parties are permitted reasonable necessary uses of
such material in connection with this action, to address their handling of such
material at the end of the litigation, and to serve the ends of justice, a protective
order for such information is justified in this matter. It is the intent of the parties
that information will not be designated as confidential for tactical reasons and that
nothing be so designated without a good faith belief that it has been maintained in a
confidential, non-public manner, and there is good cause why it should not be part
of the public record of this case.
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2.
DEFINITIONS
2.1
Action: The instant action, Thunder Studios, Inc. v. Kazal, C.D. Cal.
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Case No. 2:17-cv-00871-AB.
2.2
Challenging Party: a Party or Non-Party that challenges the
designation of information or items under this Order.
2.3
“CONFIDENTIAL” Information or Items: information (regardless of
how it is generated, stored or maintained) or tangible things that qualify for
protection under Federal Rule of Civil Procedure 26(c), and as specified above in
the Good Cause Statement.
2.4
“HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES ONLY”
Information or Items: extremely sensitive and/or private “CONFIDENTIAL”
Information or Items, the disclosure of which to another Party or Non-Party would
create a substantial risk of serious harm that could not be avoided by less restrictive
means.
2.5
Counsel: Outside Counsel of Record and House Counsel (as well as
their support staff).
2.6
Designating Party: a Party or Non-Party that designates information or
items that it produces in disclosures or in responses to discovery as
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES
ONLY.”
2.7
Disclosure or Discovery Material: all items or information, regardless
of the medium or manner in which it is generated, stored, or maintained (including,
among other things, testimony, transcripts, and tangible things), that are produced or
generated in disclosures or responses to discovery in this matter.
2.8
Expert: a person with specialized knowledge or experience in a matter
pertinent to the litigation who has been retained by a Party or its counsel to serve as
an expert witness or as a consultant in this Action.
2.9
House Counsel: attorneys who are employees of a party to this Action.
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House Counsel does not include Outside Counsel of Record or any other outside
counsel.
2.10 Non-Party: any natural person, partnership, corporation, association, or
other legal entity not named as a Party to this action.
2.11 Outside Counsel of Record: attorneys who are not employees of a
party to this Action but are retained to represent or advise a party to this Action and
have appeared in this Action on behalf of that party or are affiliated with a law firm
which has appeared on behalf of that party, and includes support staff. For purposes
of this Protective Order, The Seiden Group, notwithstanding its lack of formal
appearance in this litigation, shall be included in the definition of “Outside Counsel
of Record.”
2.12 Party: any party to this Action, including all of its officers, directors,
employees, consultants, retained experts, and Outside Counsel of Record (and their
support staffs).
2.13 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
2.14 Professional Vendors: persons or entities that provide litigation
support services (e.g., photocopying, videotaping, translating, preparing exhibits or
demonstrations, and organizing, storing, or retrieving data in any form or medium)
and their employees and subcontractors.
2.15 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -ATTORNEYS’ EYES ONLY.”
2.16 Receiving Party: a Party that receives Disclosure or Discovery
Material from a Producing Party.
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3.
SCOPE
The protections conferred by this Order cover not only Protected Material (as
defined above), but also (1) any information copied or extracted from Protected
Material; (2) all copies, excerpts, summaries, or compilations of Protected Material;
and (3) any testimony, conversations, or presentations by Parties or their Counsel
that might reveal Protected Material, other than during a court hearing or at trial.
Any use of Protected Material during a court hearing or at trial shall be
governed by the orders of the trial judge. This Order does not govern the use of
Protected Material during a court hearing or at trial.
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4.
DURATION
Once a case proceeds to trial, all of the court-filed information to be
introduced that was previously designated as confidential or maintained pursuant to
this protective order becomes public and will be presumptively available to all
members of the public, including the press, unless compelling reasons supported by
specific factual findings to proceed otherwise are made to the trial judge in advance
of the trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81
(9th Cir. 2006) (distinguishing “good cause” showing for sealing documents
produced in discovery from “compelling reasons” standard when merits-related
documents are part of court record). Accordingly, the terms of this protective order
do not extend beyond the commencement of the trial.
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5.
DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection.
Each Party or Non-Party that designates information or items for protection under
this Order must take care to limit any such designation to specific material that
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qualifies under the appropriate standards. The Designating Party must designate for
protection only those parts of material, documents, items, or oral or written
communications that qualify so that other portions of the material, documents,
items, or communications for which protection is not warranted are not swept
unjustifiably within the ambit of this Order.
Except as otherwise provided, mass, indiscriminate, or routinized
designations are prohibited. Designations that are shown to be clearly unjustified or
that have been made for an improper purpose (e.g., to unnecessarily encumber the
case development process or to impose unnecessary expenses and burdens on other
parties) may expose the Designating Party to sanctions.
If it comes to a Designating Party’s attention that information or items that it
designated for protection do not qualify for protection, that Designating Party must
promptly notify all other Parties that it is withdrawing the inapplicable designation.
5.2
Manner and Timing of Designations. Except as otherwise provided in
this Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material
that qualifies for protection under this Order must be clearly so designated before
the material is disclosed or produced.
Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic
documents, but excluding transcripts of depositions), that the Producing Party affix
at a minimum, the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -ATTORNEYS’ EYES ONLY” to each page that contains protected material. If
only a portion or portions of the material on a page qualifies for protection, the
Producing Party also must clearly identify the protected portion(s) (e.g., by making
appropriate markings in the margins).
A Party or Non-Party that makes original documents available for inspection
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need not designate them for protection until after the inspecting Party has indicated
which documents it would like copied and produced. During the inspection and
before the designation, all of the material made available for inspection shall be
deemed “CONFIDENTIAL.” After the inspecting Party has identified the
documents it wants copied and produced, the Producing Party must determine which
documents, or portions thereof, qualify for protection under this Order. Then,
before producing the specified documents, the Producing Party must affix the
“CONFIDENTIAL”, or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES
ONLY” legend to each page that contains Protected Material. If only a portion or
portions of the material on a page qualifies for protection, the Producing Party also
must clearly identify the protected portion(s) (e.g., by making appropriate markings
in the margins).
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(b) for testimony given in depositions that the Designating Party identifies
on the record, before the close of the deposition.
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(c) for information produced in some form other than documentary and
for any other tangible items, that the Producing Party affix in a prominent place on
the exterior of the container or containers in which the information is stored the
legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’
EYES ONLY.” If only a portion or portions of the information warrants protection,
the Producing Party, to the extent practicable, shall identify the protected portion(s).
5.3
Inadvertent Failures to Designate. If timely corrected, an inadvertent
failure to designate qualified information or items does not, standing alone, waive
the Designating Party’s right to secure protection under this Order for such material.
Upon timely correction of a designation, the Receiving Party must make reasonable
efforts to assure that the material is treated in accordance with the provisions of this
Order.
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6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
Timing of Challenges. Any Party or Non-Party may challenge a
designation of confidentiality at any time that is consistent with the Court’s
Scheduling Order.
6.2
Meet and Confer. The Challenging Party shall initiate the dispute
resolution process under Local Rule 37.1 et seq. Any discovery motion must strictly
comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint
stipulation pursuant to Local Rule 37-2.
6.4
Burden. The burden of persuasion in any such challenge proceeding
shall be on the Designating Party. Frivolous challenges, and those made for an
improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
other parties) may expose the Challenging Party to sanctions. Unless the
Designating Party has waived or withdrawn the confidentiality designation, all
parties shall continue to afford the material in question the level of protection to
which it is entitled under the Producing Party’s designation until the Court rules on
the challenge.
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7.
ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is
disclosed or produced by another Party or by a Non-Party in connection with this
Action only for prosecuting, defending, or attempting to settle this Action.
Protected Material may not be used in connection with any other lawsuit, action or
proceeding of any kind in any venue, nor may Protected Material be shared or
published in any manner. Such Protected Material may be disclosed only to the
categories of persons and under the conditions described in this Order. When the
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Action has been terminated, a Receiving Party must comply with the provisions of
Section 13 below (FINAL DISPOSITION).
Protected Material must be stored and maintained by a Receiving Party at a
location and in a secure manner that ensures that access is limited to the persons
authorized under this Order.
7.2
Disclosure of “CONFIDENTIAL” Information or Items. Unless
otherwise ordered by the court or permitted in writing by the Designating Party, a
Receiving Party may disclose any information or item designated
“CONFIDENTIAL” only to:
(a) the Receiving Party’s Outside Counsel of Record in this Action, as
well as employees of said Outside Counsel of Record to whom it is reasonably
necessary to disclose the information for this Action;
(b) the Receiving Party himself, or in the case of an entity, the Receiving
Party’s officers, directors, and employees (including House Counsel) of the
Receiving Party to whom disclosure is reasonably necessary for this Action;
(c) Experts (as defined in this Order) of the Receiving Party to whom
disclosure is reasonably necessary for this Action and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
(d) the Court and its personnel;
(e) court reporters and their staff;
(f) professional jury or trial consultants, mock jurors, and Professional
Vendors to whom disclosure is reasonably necessary for this Action and who have
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;
(h) during their depositions, witnesses, and attorneys for witnesses, in the
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Action to whom disclosure is reasonably necessary provided: (1) the deposing party
requests that the witness sign the “Acknowledgment and Agreement to Be Bound”
(Exhibit A); and (2) they will not be permitted to keep any confidential information
unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
unless otherwise agreed by the Designating Party or ordered by the court. Pages of
transcribed deposition testimony or exhibits to depositions that reveal Protected
Material may be separately bound by the court reporter and may not be disclosed to
anyone except as permitted under this Protective Order; and
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(i) any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by any of the parties engaged in settlement discussions.
7.3
Disclosure of “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES
ONLY” Information or Items. Unless otherwise ordered by the court or permitted in
writing by the Designating Party, a Receiving Party may disclose any information or
item designated “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES ONLY”
only to:
(a) the Receiving Party’s Outside Counsel of Record in this Action, as well
as employees of said Outside Counsel of Record to whom it is reasonably necessary
to disclose the information for this Action;
(b) Experts (as defined in this Order) of the Receiving Party to whom
disclosure is reasonably necessary for this Action and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
(c) the Court and its personnel;
(d) court reporters and their staff;
(e) professional jury or trial consultants, mock jurors, and Professional
Vendors to whom disclosure is reasonably necessary for this Action and who have
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(f) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;
(g) during their depositions, witnesses, and attorneys for witnesses, in the
Action to whom disclosure is reasonably necessary provided: (1) the deposing party
requests that the witness sign the “Acknowledgment and Agreement to Be Bound”
(Exhibit A); and (2) they will not be permitted to keep any confidential information,
unless otherwise agreed by the Designating Party or ordered by the court. Pages of
transcribed deposition testimony or exhibits to depositions that reveal Protected
Material may be separately bound by the court reporter and may not be disclosed to
anyone except as permitted under this Protective Order; and
(h) any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by any of the parties engaged in settlement discussions.
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8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED IN OTHER LITIGATION
If a Party is served with a subpoena or a court order issued in any other matter
that compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES
ONLY,” that Party must, unless otherwise prohibited by law:
(a) promptly notify in writing the Designating Party. Such notification
shall include a copy of the subpoena or court order;
(b) promptly notify in writing the party who caused the subpoena or order
to issue in the other litigation that some or all of the material covered by the
subpoena or order is subject to this Stipulated Protective Order. Such notification
shall include a copy of this Stipulated Protective Order; and
(c) cooperate with respect to all reasonable procedures sought to be
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pursued by the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with
the subpoena or court order shall not produce any information designated in this
action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’
EYES ONLY” before a determination by the court from which the subpoena or
order issued, unless the Party has obtained the Designating Party’s permission. The
Designating Party shall bear the burden and expense of seeking protection in that
court of its confidential material and nothing in these provisions should be construed
as authorizing or encouraging a Receiving Party in this Action to disobey a lawful
directive from another court.
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9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(a) The terms of this Order are applicable to information produced by a
Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL -- ATTORNEYS’ EYES ONLY.” Such information produced by
Non-Parties in connection with this litigation is protected by the remedies and relief
provided by this Order. Nothing in these provisions should be construed as
prohibiting a Non-Party from seeking additional protections.
(b) In the event that a Party is required, by a valid discovery request, to
produce a Non-Party’s confidential information in its possession, and the Party is
subject to an agreement with the Non-Party not to produce the Non-Party’s
confidential information, then the Party shall, unless otherwise prohibited by law:
(1) promptly notify in writing the Requesting Party and the Non-Party
that some or all of the information requested is subject to a confidentiality
agreement with a Non-Party;
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(2) promptly provide the Non-Party with a copy of the Protective
Order in this Action, the relevant discovery request(s), and a reasonably specific
description of the information requested; and
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(3) make the information requested available for inspection by the
Non-Party, if requested.
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(c) If the Non-Party fails to seek a protective order from this Court within
14 days of receiving the notice and accompanying information, the Receiving Party
may produce the Non-Party’s confidential information responsive to the discovery
request. If the Non-Party timely seeks a protective order, the Receiving Party shall
not produce any information in its possession or control that is subject to the
confidentiality agreement with the Non-Party before a determination by the Court.
Absent a court order to the contrary, the Non-Party shall bear the burden and
expense of seeking protection in this court of its Protected Material.
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UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
Protected Material to any person or in any circumstance not authorized under this
Protective Order, the Receiving Party must immediately, unless prohibited by law
(a) notify in writing the Designating Party of the unauthorized disclosures, (b) use
its best efforts to retrieve all unauthorized copies of the Protected Material, (c)
inform the person or persons to whom unauthorized disclosures were made of all the
terms of this Order, and (d) request such person or persons to execute the
“Acknowledgment and Agreement to Be Bound” (Exhibit A).
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INADVERTENT PRODUCTION OF PRIVILEGED OR
OTHERWISE PROTECTED MATERIAL
When a Producing Party gives notice to Receiving Parties that certain
inadvertently produced material is subject to a claim of privilege or other protection,
the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
Procedure 26(b)(5)(B). This provision is not intended to modify whatever
procedure may be established in an e-discovery order that provides for production
without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
(e), insofar as the parties reach an agreement on the effect of disclosure of a
communication or information covered by the attorney-client privilege or work
product protection, the parties may incorporate their agreement in the stipulated
protective order submitted to the Court.
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12.
MISCELLANEOUS
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
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
Protective Order, no Party waives any right it otherwise would have to object to
disclosing or producing any information or item on any ground not addressed in this
Protective Order. Similarly, no Party waives any right to object on any 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
Protected Material must comply with Civil Local Rule 79-5, and any similarlyapplicable rules or procedures shall apply in any relevant foreign jurisdiction’s
court. Protected Material may only be filed under seal pursuant to a court order
authorizing the sealing of the specific Protected Material at issue; good cause must
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be shown in the request to file under seal. If a Party’s request to file Protected
Material under seal is denied by the court, then the Receiving Party may file the
information in the public record unless otherwise instructed by the court.
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After the final disposition of this Action, within 60 days of a written request
by the Designating Party, each Receiving Party must return all Protected Material to
the Producing Party or destroy such material. As used in this subdivision, “all
Protected Material” includes all copies, abstracts, compilations, summaries, and any
other format reproducing or capturing any of the Protected Material. Whether the
Protected Material is returned or destroyed, the Receiving Party must submit a
written certification to the Producing Party (and, if not the same person or entity, to
the Designating Party) by the 60 day deadline that (1) identifies (by category, where
appropriate) all the Protected Material that was returned or destroyed and (2) affirms
that the Receiving Party has not retained any copies, abstracts, compilations,
summaries or any other format reproducing or capturing any of the Protected
Material. Notwithstanding this provision, counsel are entitled to retain an archival
copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
work product, and consultant and expert work product, even if such materials
contain Protected Material. Any such archival copies that contain or constitute
Protected Material remain subject to this Protective Order as set forth in Section 4.
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FINAL DISPOSITION
14.
Any violation of this Order may be punished by any and all appropriate
measures including, without limitation, contempt proceedings and/or monetary
sanctions.
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: 8/9/18
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/S/
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Suzanne H. Segal
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United States District/Magistrate Judge
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I,
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_________________ [print or type full address], declare under penalty of perjury that
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I have read in its entirety and understand the Stipulated Protective Order that was
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issued by the United States District Court for the Central District of California on
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_________________________
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_____________________________________. I agree to comply with and to be
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bound by all the terms of this Protective Order and I understand and acknowledge that
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failure to so comply could expose me to sanctions and punishment in the nature of
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contempt. I solemnly promise that I will not disclose in any manner any information
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or item that is subject to this Protective Order to any person or entity except in strict
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compliance with the provisions of this Order.
_____________________________
[print
or
in
the
type
full
name],
case
of
of
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I further agree to submit to the jurisdiction of the United States District Court
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for the Central District of California for the purpose of enforcing the terms of this
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Protective Order, even if such enforcement proceedings occur after termination of this
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action. I hereby appoint __________________________ [print or type full name] of
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_______________________________________ [print or type full address and
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telephone number] as my California agent for service of process in connection with
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this action or any proceedings related to enforcement of this Stipulated Protective
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Order.
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Date: ______________________________________
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City and State where sworn and signed: _________________________________
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Printed name: _______________________________
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Signature: __________________________________
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