Maria Carmela Condie v. Oxgord Incorporated

Filing 24

PROTECTIVE ORDER by Magistrate Judge Jacqueline Chooljian re Stipulation for Protective Order 23 . [NOTE CHANGES MADE BY THE COURT} (dml)

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1 2 3 Ted Luymes (Cal. Bar no. 150351) TED LUYMES LAW FIRM 140 South Lake Ave., Suite 349 Pasadena, California 91101 Tel: (626) 993-7000 4 5 6 Attorneys for Plaintiff, MARIA CARMELA CONDE 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 Plaintiff, 13 14 15 Case No. 2:17-cv-01952-CAS-JC MARIA CARMELA CONDE, STIPULATED PROTECTIVE ORDER v. 17 OXGORD INCORPORATED, a California corporation, and DOES 2 – 10, inclusive. 18 [CHANGES MADE BY COURT TO PARAGRAPHS 1C, 2.1, 3, 7.2h, 8, 9c, 12.3 & EXHIBIT A] Defendants. 16 19 20 21 22 23 1. A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, 24 proprietary or private information for which special protection from public 25 disclosure and from use for any purpose other than prosecuting and defending this 26 litigation may be warranted. Accordingly, the parties hereby stipulate to and 27 petition the Court to enter the following Stipulated Protective Order. The parties 28 acknowledge that this Order does not confer blanket protections on all disclosures -1- STIPULATED PROTECTIVE ORDER 1 or responses to discovery and that the protection it affords from public disclosure 2 and use extends only to the limited information or items that are entitled to 3 confidential treatment under applicable legal principles. 4 5 6 B. GOOD CAUSE STATEMENT This action is likely to involve the disclosure of confidential trade secrets, 7 including, but not limited to: (a) the identity of supplier(s) for the allegedly 8 infringing material; (b) the supplier’s communications with the parties, including 9 pricing information; (c) defendant’s strategies to compete with other sellers on 10 and other ecommerce platforms; and (d) profit and loss data for the 11 sale of allegedly infringing product(s). The parties acknowledge that both sides 12 regard this information as confidential and protect it from public disclosure. 13 Indeed, the public disclosure of such information may expose valuable research, 14 development, commercial, financial, technical and/or proprietary information for 15 which special protection from public disclosure and from use for any purpose 16 other than prosecution of this action is warranted. Such confidential and 17 proprietary materials and information consist of, among other things, confidential 18 business or financial information, information regarding confidential business 19 practices, or other confidential research, development, or commercial information 20 (including information implicating privacy rights of third parties), information 21 otherwise generally unavailable to the public, or which may be privileged or 22 otherwise protected from disclosure under state or federal statutes, court rules, 23 case decisions, or common law. Accordingly, to expedite the flow of information, 24 to facilitate the prompt resolution of disputes over confidentiality of discovery 25 materials, to adequately protect information the parties are entitled to keep 26 confidential, to ensure that the parties are permitted reasonable necessary uses of 27 such material in preparation for and in the conduct of trial, to address their 28 handling at the end of the litigation, and serve the ends of justice, a protective -2- STIPULATED PROTECTIVE ORDER 1 order for such information is justified in this matter. It is the intent of the parties 2 that information will not be designated as confidential for tactical reasons and that 3 nothing be so designated without a good faith belief that it has been maintained in 4 a confidential, non-public manner, and there is good cause why it should not be 5 part of the public record of this case. 6 7 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING 8 UNDER SEAL 9 The parties further acknowledge, as set forth in Section 12.3, below, that 10 this Stipulated Protective Order does not entitle them to file confidential 11 information under seal. Rather, when the parties seek permission from the court 12 to file material under seal, the parties must comply with Civil Local Rule 79-5 13 and with any pertinent orders of the assigned District Judge and Magistrate Judge. 14 There is a strong presumption that the public has a right of access to judicial 15 proceedings and records in civil cases. In connection with non-dispositive 16 motions, good cause must be shown to support a filing under seal. See Kamakana 17 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. 18 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. 19 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 20 protective orders require good cause showing), and a specific showing of good 21 cause or compelling reasons with proper evidentiary support and legal 22 justification, must be made with respect to Protected Material that a party seeks to 23 file under seal. The parties’ mere designation of Disclosure or Discovery Material 24 as CONFIDENTIAL does not - without the submission of competent evidence by 25 declaration, establishing that the material sought to be filed under seal qualifies as 26 confidential, privileged, or otherwise protectable - constitute good cause. 27 28 Further, if a party requests sealing related to a dispositive motion or trial, then compelling reasons, not only good cause, for the sealing must be shown, and -3- STIPULATED PROTECTIVE ORDER 1 the relief sought shall be narrowly tailored to serve the specific interest to be 2 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 3 2010). For each item or type of information, document, or thing sought to be 4 filed or introduced under seal in connection with a dispositive motion or trial, the 5 party seeking protection must articulate compelling reasons, supported by specific 6 facts and legal justification, for the requested sealing order. Again, competent 7 evidence supporting the application to file documents under seal must be provided 8 by declaration. Any document that is not confidential, privileged, or otherwise protectable 9 10 in its entirety will not be filed under seal if the confidential portions can be 11 redacted. If documents can be redacted, then a redacted version for public 12 viewing, omitting only the confidential, privileged, or otherwise protectable 13 portions of the document, shall be filed. Any application that seeks to file 14 documents under seal in their entirety should include an explanation of why 15 redaction is not feasible. 16 17 2. DEFINITIONS 18 2.1 Action: Maria Carmela Conde v. Oxgord Corporation U.S.D.C. Case No. 19 2:17-cv-01952-CAS-JC. 20 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 21 information or items under this Order. 22 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it 23 is generated, stored or maintained) or tangible things that qualify for protection 24 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 25 Cause Statement. 26 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 27 support staff). 28 /// -4- STIPULATED PROTECTIVE ORDER 1 2.5 Designating Party: a Party or Non-Party that designates information or items 2 that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 2.6 Disclosure or Discovery Material: all items or information, regardless of the 5 medium or manner in which it is generated, stored, or maintained (including, 6 among other things, testimony, transcripts, and tangible things), that are produced 7 or generated in disclosures or responses to discovery in this matter. 8 2.7 Expert: a person with specialized knowledge or experience in a matter 9 pertinent to the litigation who has been retained by a Party or its counsel to serve 10 as an expert witness or as a consultant in this Action. 11 2.8 House Counsel: attorneys who are employees of a party to this Action. 12 House Counsel does not include Outside Counsel of Record or any other outside 13 counsel. 14 2.9 Non-Party: any natural person, partnership, corporation, association or other 15 legal entity not named as a Party to this action. 16 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 17 this Action but are retained to represent or advise a party to this Action and have 18 appeared in this Action on behalf of that party or are affiliated with a law firm that 19 has appeared on behalf of that party, and includes support staff. 20 2.11 Party: any party to this Action, including all of its officers, directors, 21 employees, consultants, retained experts, and Outside Counsel of Record (and 22 their support staffs). 23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 24 Discovery Material in this Action. 25 2.13 Professional Vendors: persons or entities that provide litigation support 26 services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 demonstrations, and organizing, storing, or retrieving data in any form or 28 medium) and their employees and subcontractors. -5- STIPULATED PROTECTIVE ORDER 1 2.14 Protected Material: any Disclosure or Discovery Material that is designated 2 as “CONFIDENTIAL.” 3 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 4 from a Producing Party. 5 6 3. SCOPE The protections conferred by this Stipulation and Order cover not only 7 8 Protected Material (as defined above), but also (1) any information copied or 9 extracted from Protected Material; (2) all copies, excerpts, summaries, or 10 compilations of Protected Material; and (3) any testimony, conversations, or 11 presentations by Parties or their Counsel that might reveal Protected Material, 12 other than during a court hearing or at trial. 13 Any use of Protected Material during a court hearing or at trial shall be 14 governed by the orders of the presiding judge. This Order does not govern the use 15 of Protected Material during a court hearing or at trial. 16 17 4. DURATION Once a case proceeds to trial, information that was designated as 18 19 CONFIDENTIAL or maintained pursuant to this protective order used or 20 introduced as an exhibit at trial becomes public and will be presumptively 21 available to all members of the public, including the press, unless compelling 22 reasons supported by specific factual findings to proceed otherwise are made to 23 the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 24 (distinguishing “good cause” showing for sealing documents produced in 25 discovery from “compelling reasons” standard when merits-related documents are 26 part of court record). Accordingly, the terms of this protective order do not extend 27 beyond the commencement of the trial. 28 / / / -6- STIPULATED PROTECTIVE ORDER 1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for Protection. 3 Each Party or Non-Party that designates information or items for protection 4 under this Order must take care to limit any such designation to specific material 5 that qualifies under the appropriate standards. The Designating Party must 6 designate for protection only those parts of material, documents, items or oral or 7 written communications that qualify so that other portions of the material, 8 documents, items or communications for which protection is not warranted are 9 not swept unjustifiably within the ambit of this Order. Mass, indiscriminate or 10 routinized designations are prohibited. Designations that are shown to be clearly 11 unjustified or that have been made for an improper purpose (e.g., to unnecessarily 12 encumber the case development process or to impose unnecessary expenses and 13 burdens on other parties) may expose the Designating Party to sanctions. 14 If it comes to a Designating Party’s attention that information or items that it 15 designated for protection do not qualify for protection, that Designating Party 16 must promptly notify all other Parties that it is withdrawing the inapplicable 17 designation. 18 5.2 Manner and Timing of Designations. Except as otherwise provided in this 19 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 20 stipulated or ordered, Disclosure or Discovery Material that qualifies for 21 protection under this Order must be clearly so designated before the material is 22 disclosed or produced. 23 Designation in conformity with this Order requires: 24 (a) 25 but excluding transcripts of depositions or other pretrial or trial proceedings), that 26 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” 27 (hereinafter “CONFIDENTIAL legend”), to each page that contains protected 28 material. If only a portion of the material on a page qualifies for protection, the For information in documentary form (e.g., paper or electronic documents, -7- STIPULATED PROTECTIVE ORDER 1 Producing Party also must clearly identify the protected portion(s) (e.g., by 2 making appropriate markings in the margins). A Party or Non-Party that makes original documents available for inspection 3 4 need not designate them for protection until after the inspecting Party has 5 indicated which documents it would like copied and produced. During the 6 inspection and before the designation, all of the material made available for 7 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 8 identified the documents it wants copied and produced, the Producing Party must 9 determine which documents, or portions thereof, qualify for protection under this 10 Order. Then, before producing the specified documents, the Producing Party must 11 affix the “CONFIDENTIAL legend” to each page that contains Protected 12 Material. If only a portion of the material on a page qualifies for protection, the 13 Producing Party also must clearly identify the protected portion(s) (e.g., by 14 making appropriate markings in the margins). 15 (b) 16 Disclosure or Discovery Material on the record, before the close of the deposition 17 all protected testimony. 18 (c) 19 other tangible items, that the Producing Party affix in a prominent place on the 20 exterior of the container or containers in which the information is stored the 21 legend “CONFIDENTIAL.” If only a portion or portions of the information 22 warrants protection, the Producing Party, to the extent practicable, shall identify 23 the protected portion(s). 24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 25 to designate qualified information or items does not, standing alone, waive the 26 Designating Party’s right to secure protection under this Order for such material. 27 /// 28 /// for testimony given in depositions that the Designating Party identifies the for information produced in some form other than documentary and for any -8- STIPULATED PROTECTIVE ORDER 1 Upon timely correction of a designation, the Receiving Party must make 2 reasonable efforts to assure that the material is treated in accordance with the 3 provisions of this Order. 4 5 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 7 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 8 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 9 process under Local Rule 37-1 et seq. 10 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 11 stipulation pursuant to Local Rule 37-2. 12 6.4 The burden of persuasion in any such challenge proceeding shall be on the 13 Designating Party. Frivolous challenges, and those made for an improper purpose 14 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 15 expose the Challenging Party to sanctions. Unless the Designating Party has 16 waived or withdrawn the confidentiality designation, all parties shall continue to 17 afford the material in question the level of protection to which it is entitled under 18 the Producing Party’s designation until the Court rules on the challenge. 19 20 7. ACCESS TO AND USE OF PROTECTED MATERIAL 21 7.1 Basic Principles. A Receiving Party may use Protected Material that is 22 disclosed or produced by another Party or by a Non-Party in connection with this 23 Action only for prosecuting, defending or attempting to settle this Action. Such 24 Protected Material may be disclosed only to the categories of persons and under 25 the conditions described in this Order. When the Action has been terminated, a 26 Receiving Party must comply with the provisions of section 13 below (FINAL 27 DISPOSITION). Protected Material must be stored and maintained by a 28 Receiving Party at a location and in a secure manner that ensures that access is -9- STIPULATED PROTECTIVE ORDER 1 limited to the persons authorized under this Order. 2 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 3 ordered by the court or permitted in writing by the Designating Party, a Receiving 4 Party may disclose any information or item designated “CONFIDENTIAL” only 5 to: 6 a. 7 employees of said Outside Counsel of Record to whom it is reasonably necessary 8 to disclose the information for this Action; 9 b. the Receiving Party’s Outside Counsel of Record in this Action, as well as the officers, directors, and employees (including House Counsel) of the 10 Receiving Party to whom disclosure is reasonably necessary for this Action; 11 c. 12 is reasonably necessary for this Action and who have signed the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 d. the court and its personnel; 15 e. court reporters and their staff; 16 f. professional jury or trial consultants, mock jurors, and Professional Vendors 17 to whom disclosure is reasonably necessary for this Action and who have signed 18 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 g. 20 custodian or other person who otherwise possessed or knew the information; 21 h. 22 Action to whom disclosure is reasonably necessary provided: (1) the deposing 23 party requests that the witness sign the “Acknowledgment and Agreement to Be 24 Bound” form attached as Exhibit A hereto; and (2) they will not be permitted to 25 keep any confidential information unless they sign the “Acknowledgment and 26 Agreement to Be Bound” attached as Exhibit A, unless otherwise agreed by the 27 Designating Party or ordered by the court. Pages of transcribed deposition 28 testimony or exhibits to depositions that reveal Protected Material may be Experts (as defined in this Order) of the Receiving Party to whom disclosure the author or recipient of a document containing the information or a during their depositions, witnesses, and attorneys for witnesses, in the -10- STIPULATED PROTECTIVE ORDER 1 separately bound by the court reporter and may not be disclosed to anyone except 2 as permitted under this Stipulated Protective Order; and 3 i. 4 agreed upon by any of the parties engaged in settlement discussions. any mediator or settlement officer, and their supporting personnel, mutually 5 6 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 7 8 If a Party is served with a subpoena or a court order issued in other litigation that 9 compels disclosure of any information or items designated in this Action as 10 “CONFIDENTIAL,” that Party must: 11 a. 12 include a copy of the subpoena or court order; 13 b. 14 issue in the other litigation that some or all of the material covered by the 15 subpoena or order is subject to this Protective Order. Such notification shall 16 include a copy of this Stipulated Protective Order; and 17 c. 18 the Designating Party whose Protected Material may be affected. promptly notify in writing the Designating Party. Such notification shall promptly notify in writing the party who caused the subpoena or order to cooperate with respect to all reasonable procedures sought to be pursued by If the Designating Party timely seeks a protective order, the Party served 19 20 with the subpoena or court order shall not produce any information designated in 21 this action as “CONFIDENTIAL” before a determination by the court from which 22 the subpoena or order issued, unless the Party has obtained the Designating 23 Party’s permission, or unless otherwise required by the law or court order. The 24 Designating Party shall bear the burden and expense of seeking protection in that 25 court of its confidential material and nothing in these provisions should be 26 construed as authorizing or encouraging a Receiving Party in this Action to 27 disobey a lawful directive from another court. 28 / / / -11- STIPULATED PROTECTIVE ORDER 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 2 3 a. The terms of this Order are applicable to information produced by a Non- 4 Party in this Action and designated as “CONFIDENTIAL.” Such information 5 produced by Non-Parties in connection with this litigation is protected by the 6 remedies and relief provided by this Order. Nothing in these provisions should be 7 construed as prohibiting a Non-Party from seeking additional protections. 8 b. 9 a Non-Party’s confidential information in its possession, and the Party is subject 10 to an agreement with the Non-Party not to produce the Non-Party’s confidential 11 information, then the Party shall: 12 1. 13 some or all of the information requested is subject to a confidentiality agreement 14 with a Non-Party; 15 2. 16 Order in this Action, the relevant discovery request(s), and a reasonably specific 17 description of the information requested; and 18 3. 19 requested. 20 c. 21 for by Local Rules 45-1 and 37-1, et seq. within 14 days of receiving the notice 22 and accompanying information or fails contemporaneously to notify the 23 Receiving Party that it has done so, the Receiving Party may produce the Non- 24 Party’s confidential information responsive to the discovery request. If an 25 unrepresented Non-Party fails to seek a protective order from this court within 14 26 days of receiving the notice and accompanying information, the Receiving Party 27 may produce the Non-Party’s confidential information responsive to the discovery 28 request. If the Non-Party timely seeks a protective order, the Receiving Party In the event that a Party is required, by a valid discovery request, to produce promptly notify in writing the Requesting Party and the Non-Party that promptly provide the Non-Party with a copy of the Stipulated Protective make the information requested available for inspection by the Non-Party, if If a Non-Party represented by counsel fails to commence the process called -12- STIPULATED PROTECTIVE ORDER 1 shall not produce any information in its possession or control that is subject to the 2 confidentiality agreement with the Non-Party before a determination by the court 3 unless otherwise required by the law or court order. Absent a court order to the 4 contrary, the Non-Party shall bear the burden and expense of seeking protection in 5 this court of its Protected Material. 6 7 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 8 If a Receiving Party learns that, by inadvertence or otherwise, it has 9 disclosed Protected Material to any person or in any circumstance not authorized 10 under this Stipulated Protective Order, the Receiving Party must immediately (a) 11 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 12 best efforts to retrieve all unauthorized copies of the Protected Material, (c) 13 inform the person or persons to whom unauthorized disclosures were made of all 14 the terms of this Order, and (d) request such person or persons to execute the 15 “Acknowledgment and Agreement to Be Bound” attached hereto as Exhibit A. 16 17 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 18 OTHERWISE PROTECTED MATERIAL 19 When a Producing Party gives notice to Receiving Parties that certain 20 inadvertently produced material is subject to a claim of privilege or other 21 protection, the obligations of the Receiving Parties are those set forth in Federal 22 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 23 whatever procedure may be established in an e-discovery order that provides for 24 production without prior privilege review. Pursuant to Federal Rule of Evidence 25 502(d) and (e), insofar as the parties reach an agreement on the effect of 26 disclosure of a communication or information covered by the attorney-client 27 privilege or work product protection, the parties may incorporate their agreement 28 in the stipulated protective order submitted to the court. -13- STIPULATED PROTECTIVE ORDER 1 12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 3 person to seek its modification by the Court in the future. 4 12.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order, no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in 7 this Stipulated Protective Order. Similarly, no Party waives any right to object on 8 any ground to use in evidence of any of the material covered by this Protective 9 Order. 10 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 11 Material must comply with Civil Local Rule 79-5 and with any pertinent orders of 12 the assigned District Judge and Magistrate Judge. If a Party's request to file 13 Protected Material under seal is denied by the court, then the Receiving Party may 14 file the information in the public record unless otherwise instructed by the court. 15 16 17 13. FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 4, within 18 60 days of a written request by the Designating Party, each Receiving Party must 19 return all Protected Material to the Producing Party or destroy such material. As 20 used in this subdivision, “all Protected Material” includes all copies, abstracts, 21 compilations, summaries, and any other format reproducing or capturing any of 22 the Protected Material. Whether the Protected Material is returned or destroyed, 23 the Receiving Party must submit a written certification to the Producing Party 24 (and, if not the same person or entity, to the Designating Party) by the 60 day 25 deadline that (1) identifies (by category, where appropriate) all the Protected 26 Material that was returned or destroyed and (2) affirms that the Receiving Party 27 has not retained any copies, abstracts, compilations, summaries or any other 28 format reproducing or capturing any of the Protected Material. Notwithstanding -14- STIPULATED PROTECTIVE ORDER 1 this provision, Counsel are entitled to retain an archival copy of all pleadings, 2 motion papers, trial, deposition, and hearing transcripts, legal memoranda, 3 correspondence, deposition and trial exhibits, expert reports, attorney work 4 product, and consultant and expert work product, even if such materials contain 5 Protected Material. Any such archival copies that contain or constitute Protected 6 Material remain subject to this Protective Order as set forth in 7 Section 4 (“DURATION”) 8 9 14. VIOLATION 10 Any violation of this Order may be punished by appropriate measures including, 11 without limitation, contempt proceedings and/or monetary sanctions. 12 13 IT IS SO STIPULATED BY AND THROUGH COUNSEL OF RECORD. 14 15 DATED: August 28, 2017 TED LUYMES LAW FIRM 16 By: 17 Ted H. Luymes Attorney for Plaintiff 18 /s/ 19 20 DATED: September 5, 2017 LAW OFFICE OF ARYEH KAUFMAN By: 21 Aryeh Kaufman Attorney for Defendant 22 23 /s/ FOR GOOD CAUSE SHOWN, IT IS SO ORDERED AS MODIFIED. 24 25 26 27 DATED: October 6, 2017 ___________/s/________________ Hon. Jacqueline Chooljian, U.S. Magistrate Judge 28 -15- STIPULATED PROTECTIVE ORDER 1 2 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 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 Maria Carmela Conde v. Oxgord Corporation U.S.D.C. Case No. 2:17-cv-01952-CAS-JC. 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 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: _____________ 20 City and State where sworn and signed: _________________________________ 21 Printed name: 22 23 Signature: __________________________________ 24 25 26 27 28 -16- STIPULATED PROTECTIVE ORDER

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