Enrique B. Roque v. Home Depot U.S.A., INC.,

Filing 15

PROTECTIVE ORDER by Magistrate Judge Rozella A. Oliver granting Stipulated Protective Order 13 (sbu)

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1 2 3 4 5 6 Michael J. Sexton, CA Bar No. 153435 michael.sexton@ogletree.com Michael E. Olsen, CA Bar No. 307358 michael.olsen@ogletree.com OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Park Tower, Suite 1500 695 Town Center Drive Costa Mesa, CA 92626 Telephone: 714.800.7900 Facsimile: 714.754.1298 7 Attorneys for Defendant HOME DEPOT U.S.A., INC. 8 Gregory P. Wong, CA Bar No. 204502 9 ADEPT EMPLOYMENT LAW, APC 10880 Wilshire Boulevard, Suite 1101 10 Los Angeles, CA 90012 Telephone: 213.505.6283 11 Facsimile: 213.947.4584 greg.wong@adeptemploymentlaw.com 12 Attorneys for Plaintiff 13 Enrique B. Roque 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION 16 17 ENRIQUE B. ROQUE, an individual, Case No. 2:17-CV-02464 PA (RAOx) 18 Assigned to: Percy Anderson, District Judge Rozella A. Oliver, Magistrate Judge 19 Plaintiff, vs. 20 HOME DEPOT U.S.A., INC., a Delaware STIPULATED PROTECTIVE 21 22 corporation. ORDER Defendant. [Filed Concurrently with [Proposed] Protective Order] 23 Complaint Filed: March 30, 2016 Trial Date: None Set 24 25 26 27 ~1876677.DOCX 28 1 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 IT IS HEREBY STIPULATED by and between Plaintiff ENRIQUE B. 2 ROQUE (hereinafter referred to as “Plaintiff”) and Defendant HOME DEPOT 3 U.S.A., INC. (hereinafter referred to as “Defendant” and/or “Home Depot”), through 4 their respective attorneys of record, that a Protective Order be entered by this Court 5 as follows: 6 This Stipulation and Protective Order shall be applicable to and shall apply to 7 the production and exchange of all document requests and documents, interrogatories 8 and answers to interrogatories, depositions, request for admissions, and responses to 9 requests for admissions, exhibits, and pleadings and all other information exchanged 10 and furnished in this Action by the Parties that the parties customarily treat as 11 confidential, proprietary, and/or a trade secret as defined by California Civil Code 12 Section 3426.1. 13 1. SCOPE 14 (a) The parties acknowledge that discovery may require disclosure of 15 information that is private and personal or confidential and proprietary, specifically 16 personnel records, personnel policies, employment offers, competitive analyses, 17 income statements, employee, client, or customer personal information (including, 18 but not limited to medical, age, and contact information), medical records, and 19 financial records and statements, along with other trade secret information as defined 20 in California Civil Code Section 3426.1. As a result, the parties agree to enter into a 21 Protective Order on the following terms to ensure the continuing confidentiality of 22 such information. The parties further acknowledge that this Order does not confer 23 blanket protections on all disclosures or responses to discovery and that the 24 protection it affords extends only to the limited information or items that are entitled 25 under the applicable legal principles to treatment as confidential. 26 (b) This Protective Order shall limit the use or disclosure of documents, 27 deposition testimony, and related information which are or which embody or 28 disclose any information falling with the scope of Paragraph (1)(a) and designated ~1876677.DOCX 2 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 hereunder as “Confidential,” and shall apply to: (i) 2 All such documents, including those produced by third parties, 3 designated as “Confidential” in accordance with the terms of this Protective Order 4 and the applicable legal standards; (ii) 5 Portions of deposition testimony and transcripts and exhibits 6 thereto which include, refer or relate to any Confidential Information; (iii) 7 All information, copies, extracts and complete or partial 8 summaries prepared or derived from Confidential Information; and (iv) 9 Portions of briefs, memoranda or any writing filed with or 10 otherwise supplied to the Court, which include or refer to any such Confidential 11 12 Information. (c) Any person designating documents, testimony, or other information as 13 “Confidential” hereunder asserts that he or she believes in good faith that such 14 material is Confidential Information which falls within the scope of Section (1)(a) 15 and is not otherwise available to the public generally. Each party or non-party that 16 designates information or items for protection under this Order must take care to 17 limit any such designation to specific material that qualifies under the appropriate 18 standards. A Designating Party must take care to designate for protection only those 19 parts of material, documents, items, or oral or written communications that qualify so 20 that other portions of the material, documents, items, or communications for which 21 protection is not warranted are not swept unjustifiably within the ambit of this Order. 22 2. DESIGNATION OF DOCUMENTS AND DEPOSITIONS 23 (a) Designation of a document as “Confidential” shall be made by stamping 24 or writing CONFIDENTIAL on the document(s). Alternatively, the parties may 25 designate documents as “Confidential” by producing the documents with a letter 26 designating the documents by Bates number as “Confidential.” The parties shall 27 make all reasonable effort to designate as “Confidential” only those documents that 28 they reasonably believe constitute personnel records, personnel policies, employment ~1876677.DOCX 3 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 offers, competitive analyses, income statements, employee, client or customer 2 personal information, medical records, financial records and statements, and trade 3 secret information as defined in California Civil Code Section 3426.1. The failure to 4 designate documents as “Confidential” at the time of production shall not constitute 5 a waiver of the protection of this Order and any party may, at any time up to 30 days 6 before the date of discovery cut-off in this action, designate any documents or 7 information produced as “Confidential” that have not as yet been so designated. 8 Stamping the legend “Confidential” on the cover of any multi-page document shall 9 designate all pages of the document as confidential, unless otherwise indicated by the 10 Designating Party, but only if the entire document is produced in a bound or 11 otherwise intact manner. 12 (b) Designation of a deposition or other pretrial testimony, or portions 13 thereof, as “Confidential” shall be made by a statement on the record by counsel for 14 the party or other person making the claim of confidentiality at the time of such 15 testimony. The portions of depositions so designated as “Confidential” shall be 16 taken only in the presence of persons qualified to receive such information pursuant 17 to the terms of this Protective Order: the parties and their attorneys and staff, the 18 court reporter, videographer, the deponent, and the deponent’s attorney. Failure of 19 any other person to comply with a request to leave the deposition room will 20 constitute sufficient justification for the witness to refuse to answer any question 21 calling for disclosure of Confidential Information so long as persons are in 22 attendance who are not entitled by this Protective Order to have access to such 23 information. 24 Confidential Information, instruct the court reporter to segregate such portions of the 25 deposition in a separate transcript designated as “Confidential.” Portions of such 26 deposition transcripts shall be clearly marked as “Confidential” on the cover or on 27 each page, as appropriate. The parties may, but need not in order to designate material as ~1876677.DOCX 28 (c) Any party may designate documents produced or portions of 4 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 depositions taken as containing Confidential Information even if not initially marked 2 as “Confidential” in accordance with the terms of this Protective Order by so 3 advising counsel for each other party in writing and by reproducing said documents 4 with the required confidential designation. Thereafter, each such document or 5 transcript shall be treated in accordance with the terms of this Protective Order; 6 provided, however, that there shall be no liability for any disclosure or use of such 7 documents or transcripts, or the Confidential Information contained therein, which 8 occurred prior to actual receipt of such written notice. Any person who receives 9 actual notice of any such designation of previously produced documents or 10 deposition transcripts as containing Confidential Information shall thereafter treat 11 such information as if it had been designated as “Confidential” at the time he, she, or 12 it first received it in connection with this matter. 13 (d) Inadvertent failure to designate Confidential Information shall not be 14 construed as a waiver, in whole or in part, and may be corrected by the producing 15 party by designating documents produced or portions of depositions taken as 16 containing Confidential Information, even if not initially marked as “Confidential,” 17 in accordance with the terms of this Protective Order and, specifically, Paragraph 18 2(c) above. 19 3. INFORMATION 20 21 LIMITATIONS ON DISCLOSURE OF CONFIDENTIAL (a) No Confidential Information shall be disclosed by anyone receiving 22 such information to anyone other than those persons designated herein. In no event 23 shall Confidential Information be used, either directly or indirectly, by anyone 24 receiving such information for any business, commercial or competitive purpose or 25 for any purpose whatsoever other than the direct furtherance of the litigation of this 26 action in accordance with the provisions of this Protective Order. 27 (b) Confidential Information shall not be disclosed by any person who has ~1876677.DOCX 28 received such information through discovery in this action to any other person, 5 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 except to: 2 (i) The parties; 3 (ii) Attorneys of record for the parties and their firms’ associates, 4 clerks and other employees involved in the conduct of this litigation, and any court 5 reporters, videographers, or interpreters engaged to assist the parties in discovery; (iii) 7 Home Depot’s, its subsidiaries’, or its affiliates’ in-house (iv) 6 Non-party experts and consultants engaged by counsel for the counsel; 8 9 purpose of preparing or assisting in this litigation, and those experts’ respective 10 clerks and employees involved in assisting them in this litigation, to the extent 11 deemed necessary by counsel; (v) 12 The Court, its officers, Court reporters and similar personnel, 13 provided further that Confidential Information lodged with the Court under seal is 14 subject to further evaluation by the Court; (vi) 15 Any person as to which it is apparent from the face of a document 16 was either an author, recipient, had knowledge of the contents therein, or was 17 otherwise entitled to view the Confidential Information prior to the intended 18 disclosure in this action; and 19 (vii) Any other potential witnesses whose testimony may be used in 20 connection with the present case who has complied with Paragraph 3(c) immediately 21 below. (viii) Any mediator or other third-party neutral the parties agree to use. 22 23 (c) Before any person described in Paragraphs 3(b)(iv) and (vii) receives or 24 is shown any document or information which has been designated as Confidential, 25 such person shall be given a copy of this Protective Order and shall agree in writing, 26 in the form of the Acknowledgment and Agreement attached hereto as Exhibit A, to 27 be bound by the terms hereof. The original of each such Acknowledgment and ~1876677.DOCX 28 Agreement shall be maintained by counsel and, if a witness appears at deposition or 6 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 at trial and represents that he or she previously executed an Acknowledgment, it 2 shall be produced for inspection by opposing counsel upon request. Any counsel 3 may require the other counsel to provide a copy of the Acknowledgment and 4 Agreement signed by a witness at a deposition before the witness is deposed with 5 regard to any Confidential Information. 6 7 (d) Nothing in this Protective Order shall be construed to require execution of the written Acknowledgment and Agreement referred to in Paragraph 3(c) above, 8 or to prevent disclosure of Confidential Information, by the party producing and 9 10 designating such Confidential Information, or by any employee of such party. (e) The substance or content of Confidential Information, as well as all 11 notes and memoranda relating thereto, shall not be disclosed to anyone other than as 12 set forth in Paragraphs 3(b)(i)-(vii) above. 13 4. FILING DOCUMENTS UNDER SEAL 14 (a) If a Party wishes to submit a document to the Court which the other 15 Party has designated as Confidential or which contains Confidential Information and 16 which has not been successfully challenged under Paragraph 5 below, the submitting 17 Party shall notify the Designating Party, in writing, of both the exact material which 18 the Party intends to submit to the Court and the reason(s) and legal ground(s) for 19 submitting the material under seal at least 30 days prior to the date on which the 20 Party intends to make the submission, so as to provide the Designating Party 21 sufficient time to determine whether it needs to bring a motion ordering that the 22 material be filed under seal. Any such motion must comply with the procedures set 23 forth in Local Rule 79-5 and must also comply with Federal Rule of Civil Procedure 24 26(c)(1). The written application and proposed order shall be presented to the judge 25 along with the document intended to be submitted for filing under seal. The original 26 and judge’s copy of the document shall be sealed in separate envelopes with a copy 27 of the title page attached to the front of each envelope. If only a portion of the 28 document is sealable, then both the copy lodged with the Clerk and the judge’s copy ~1876677.DOCX 7 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 shall have the sealable portions identified by notation or highlighting of the text. 2 The Application and Order to Seal, along with the material to be placed under 3 seal, shall not be electronically filed but shall be filed manually in the manner 4 prescribed by Local Rule 79-5. 5 electronically filed, identifying all materials being manually filed. 6 (b) A Notice of Manual Filing shall also be Any party requesting that a record be filed under seal must comply with 7 Local Rule 79-5. The Parties agree and recognize that Confidential Information or 8 any paper containing Confidential Information cannot be filed under seal based 9 solely upon this stipulated Protective Order. 10 5. CHALLENGE TO CONFIDENTIALITY DESIGNATION 11 Any party that wishes to challenge the designation of a document or other 12 information as “Confidential” must identify the documents or information for which 13 it is challenging the designation within 30 days after their production. 14 Designating Party may, for good cause shown, bring a motion before the Court 15 requesting that the Court confirm the designation of any document or information as 16 “Confidential.” The party asserting the designation as “Confidential” shall have the 17 burden of establishing good cause for the designation. However, the Court shall be 18 authorized to award the moving party attorneys’ fees as a sanction if the challenge to 19 the “Confidential” designation was made in bad faith or was frivolous. 20 interested parties or other persons shall attempt to resolve such disagreements before The The 21 submitting them to the Court pursuant to Local Rule 37-1. Pending resolution of any 22 dispute concerning such designation, all parties and persons governed by this 23 Protective Order shall treat all documents and information previously designated as 24 “Confidential” as protected from further disclosure by this Protective Order. 25 6. SURVIVAL OF ORDER - RETURN OF DOCUMENTS 26 (a) The provisions of this Order shall continue in effect until otherwise 27 ordered by the Court, or after notice and an opportunity to be heard is afforded to the 28 parties to this action. The final determination or settlement of this action shall not ~1876677.DOCX 8 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 relieve any person who has received Confidential Information or agreed to be bound 2 by the terms of this Protective Order of his, her, or its obligations under this 3 stipulation and Order. The Court shall retain jurisdiction after such final 4 determination or settlement to enforce the provisions of this Order. Upon 5 completion of the litigation, all documents (including copies of documents) 6 containing Confidential Information shall be destroyed or returned to counsel for the 7 producing party, except that (a) documents on which any person has made notations 8 may be destroyed and not returned, and (b) the parties’ respective attorneys of record 9 may retain one copy of each such document for use in connection with any disputes 10 which may arise under the Court’s retention of jurisdiction as provided for herein. 11 Within ninety days (90) of the conclusion of this litigation, the attorneys for the 12 receiving party shall provide the attorneys for the producing party a certificate 13 representing that such return or destruction was made. 14 (b) Except as provided in Paragraphs 4 or 6 hereof, documents or things 15 containing the other party’s Confidential Information shall at all times be in the 16 physical possession of those persons qualifying under Paragraph 3 hereunder, or kept 17 by counsel of record at the premises regularly maintained by such counsel of record 18 as and for their respective law offices. 19 7. USE OF DOCUMENTS AT TRIAL 20 This Stipulation and Protective Order, except as provided in Paragraph 4, shall 21 not apply to information designated or marked Confidential hereunder which is used 22 at any evidentiary hearing or trial in this action. The parties hereby reserve their 23 rights to use, or seek to limit the disclosure of, confidential information at any such 24 hearing or trial. 25 8. 26 Nothing in this Protective Order shall limit the use by any party, person or 27 entity of his, her, or its own document or information for legitimate business 28 purposes unrelated to this litigation, even if such documents or information have USE OF OWN DOCUMENTS BY PRODUCING PARTY ~1876677.DOCX 9 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 been designated as “Confidential.” 2 9. APPLICATIONS TO COURT 3 (a) This Protective Order shall not preclude or limit any party’s right to 4 oppose or object to discovery on any ground which would be otherwise available. 5 This Protective Order shall not preclude or limit any party’s right to seek in camera 6 review or to seek further and additional protection against or limitation upon 7 production or dissemination of information produced in response to discovery, 8 including documents and their contents. 9 (b) Any person to or by whom disclosure or inspection is made in violation 10 of this Protective Order, and who has knowledge of this Protective Order, shall be 11 bound by the terms hereof. 12 (c) The parties hereto, and all other persons who receive Confidential 13 Information pursuant hereto, agree that any party or other person injured by a 14 violation of this Order does not have an adequate remedy at law and that an 15 injunction against such violation is an appropriate remedy. In the event any person 16 shall violate or threaten to violate any terms of this Order, the parties agree that the 17 aggrieved party may immediately apply to obtain injunctive relief against any such 18 person. In the event the aggrieved party shall do so, the responding person subject to 19 the provisions of this Order shall not employ as a defense thereto the claim that the 20 aggrieved party has an adequate remedy at law. Any persons subject to the terms of 21 this Order agree that the Court shall retain jurisdiction over it and them for the 22 purposes of enforcing this Order, including but not limited to issuing an injunction. 23 In addition to injunctive relief, as specified herein, the Court may impose monetary 24 and/or issue sanctions, as well as other relief deemed appropriate under the 25 circumstances for a violation of this Protective Order. 26 (d) If any deponent required under the terms of this Protective Order to 27 execute the written Acknowledgment and Agreement described in Paragraph 3(c) ~1876677.DOCX 28 above refuses to do so, the parties may complete the deposition on other matters 10 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 and/or adjourn it and move the Court for any appropriate relief, including (without 2 limitation) relief from this Protective Order as to that deponent, or an order that the 3 deponent shall execute the written agreement described in Paragraph 3(c) above, or 4 an order that deponent shall be bound by the terms of this Protective Order. Any 5 non-party whose Confidential Information is the subject of such a motion shall be 6 given notice thereof. 7 10. AGREEMENT TO COOPERATE 8 The parties hereto and their respective attorneys of record agree that, when one 9 party’s attorney requests a deponent to sign the written Acknowledgment and 10 Agreement described in Paragraph 3(c) above, the other party’s attorney will join in 11 such request, unless that attorney has a good faith basis for refusing to join in such a 12 request; provided, however, that this requirement shall not apply with respect to any 13 deponent who is represented at his or her deposition by an attorney of record for any 14 party hereto (including any member or associate of their respective law firms). An 15 attorney’s request to sign such Acknowledgment pursuant to this Paragraph shall not 16 be construed to constitute legal advice to the deponent, but shall and may be stated to 17 be simply a request to facilitate discovery in this action. 18 11. NO ADMISSIONS 19 Neither entering into this Stipulation for Protective Order, nor receiving any 20 documents or other information designated as “Confidential” shall be construed as an 21 agreement or admission: (1) that any document or information designated as 22 “Confidential” is in fact Confidential Information; (2) as to the correctness or truth of 23 any allegation made or position taken relative to any matter designated as 24 “Confidential”; or (3) as to the authenticity, competency, relevancy or materiality of 25 any information or document designated as “Confidential.” 26 /// 27 /// 28 /// ~1876677.DOCX 11 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 12. 1 NO WAIVER OF PRIVILEGES OR OBJECTIONS TO ADMISSIBILITY 2 3 Nothing in this Protective Order shall be construed as requiring disclosure of 4 Confidential Information, including, but not limited to, materials subject to 5 protection under the attorney-client privilege and/or attorney work product doctrine, 6 the trade secrets privilege, or under any other applicable privileges or rights of 7 privacy, or requiring disclosure of Confidential Information that is otherwise beyond 8 the scope of permissible discovery. Further, nothing in this Protective Order shall be 9 construed as a waiver by a party of any objections that might be raised as to the 10 admissibility at trial of any evidentiary materials. 11 13. DISCLOSURE IN VIOLATION OF ORDER 12 If any Confidential Information is disclosed to any person other than in the 13 manner authorized by this Protective Order, the party responsible for the disclosure 14 must immediately, in writing, notify the opposing party and the Designating Party of 15 all pertinent facts relating to such disclosure, and without prejudice to the rights and 16 remedies of the Designating Party, make every effort to prevent further unauthorized 17 disclosure. 18 14. MODIFICATION - FURTHER AGREEMENTS 19 Nothing contained herein shall preclude any party from seeking from a Court 20 modification, or relief from any aspect, of this Stipulated Protective Order upon 21 proper notice, nor shall anything contained herein be construed as to preclude the 22 parties from entering into other written agreements designed to protect Confidential 23 Information. 24 25 /// 26 /// 27 /// 28 /// ~1876677.DOCX 12 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 15. COUNTERPARTS 2 This Stipulation for Protective Order may be executed in counterparts, each of 3 which shall be deemed an original and which together shall constitute one 4 instrument. 5 6 DATED: June 1, 2017 7 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 8 9 By: /s/ MICHAEL E. OLSEN________ Michael J. Sexton Michael E. Olsen Attorneys for Defendant HOME DEPOT U.S.A., INC. 10 11 12 DATED: June 1, 2017 ADEPT EMPLOYMENT LAW, APC 13 14 15 By: /s/ GREGORY P. WONG_________ Gregory P. Wong Attorneys for Plaintiff Enrique B. Roque 16 17 18 19 20 21 22 23 24 25 26 27 ~1876677.DOCX 28 13 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 2 EXHIBIT A - ACKNOWLEDGEMENT AND AGREEMENT FOR PROTECTIVE ORDER 3 I, ________________________________________, hereby certify that: 4 1. My present address is _____________________________. 5 2. My present employer is ___________________________. 6 3. My present occupation or job description is _____________________. 7 4. I have received a copy of the Protective Order in the above-captioned 8 case and agree to be bound by the terms of the Protective Order. 9 5. I have carefully read and understand the provisions of the Protective 10 Order. 11 6. I will hold in confidence and not disclose to anyone not qualified under 12 the Protective Order, any Confidential Information or any portion or substance 13 thereof provided to me in the course of this litigation. 14 7. I will return all materials containing Confidential Information or any 15 portions or copies, summaries, abstracts or indices thereof, which come into my 16 possession, and documents or things that I prepared relating thereto and containing 17 such Confidential Information, to counsel for the party by whom I am retained or 18 employed, or to counsel by whom I am retained or employed, when my services in 19 this matter have been concluded. 20 8. I understand that if I violate the provisions of this Protective Order, I 21 may be subject to sanctions by the Court, among other things. 22 9. I hereby submit to the jurisdiction of the United States District Court for 23 the Central District of California for the purpose of enforcement of this Protective 24 Order against me. 25 I declare under penalty of perjury under the laws of the State of California and 26 the United States of America that the foregoing is true and correct. 27 ~1876677.DOCX 28 Dated:_________________ Signature:_________________________________ 14 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) 1 2 3 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION 4 5 ENRIQUE B. ROQUE, an individual, Plaintiff, 6 7 vs. Case No. 2:17-CV-02464 PA (RAOx) Assigned to: Percy Anderson, District Judge Rozella A. Oliver, Magistrate Judge 8 HOME DEPOT U.S.A., INC., a Delaware PROTECTIVE ORDER corporation. 9 Defendant. [Filed Concurrently with [Proposed] Protective Order] 10 Complaint Filed: March 30, 2016 Trial Date: None Set 11 12 13 14 ORDER 15 16 17 18 19 20 21 GOOD CAUSE APPEARING THEREFOR, IT IS HEREBY ORDERED THAT the provisions of the concurrently filed stipulation between the parties Plaintiff ENRIQUE B. ROQUE and Defendant HOME DEPOT U.S.A., Inc. regarding the use and protection of Confidential Information (the “Stipulated Protective Order”) shall be entered as the Order of the Court and be binding upon the parties. 22 23 24 DATED: June 2, 2017 25 ROZELLA A. OLVER UNITED STATES MAGISTRATE JUDGE 26 23992504.1 27 ~1876677.DOCX 28 15 STIPULATED PROTECTIVE ORDER Case No. 2:17-CV-02464 PA (RAOx) CERTIFICATE OF SERVICE Enrique B. Roque v. Home Depot U.S.A., Inc. 1 2 I am and was at all times herein mentioned over the age of 18 years and not a party to the action in which this service is made. At all times herein mentioned I 4 have been employed in the County of Orange in the office of a member of the bar of this court at whose direction the service was made. My business address is 695 Town Center Drive, Suite 1500, Costa Mesa, CA 92626. 5 3 6 On June 2, 2017, I served the following document(s): STIPULATED PROTECTIVE ORDER 7 8 by placing 9 (the original) (a true copy thereof) in a sealed envelope addressed as follows: Attorneys for Plaintiff ENRIQUE B. ROQUE Gregory P. Wong ADEPT EMPLOYMENT LAW, APC 10880 Wilshire Blvd., Suite 1101 11 Los Angeles, CA 90012 Tel. 213.505.6283 12 Fax 213.947.4584 greg.wong@adeptemploymentlaw.com 13 10 14 15 16 17 18 19 20 21 BY CM/ECF SYSTEM: I caused the above-referenced document(s) to be sent by electronic transmittal to the Clerk’s Office using the CM/ECF System for filing which generated a Notice of Electronic Filing to the CM/ECF registrants in this case. BY MAIL: I placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with the practice of Ogletree, Deakins, Nash, Smoak & Stewart, P.C.’s practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. BY MESSENGER SERVICE: I served the documents by placing them in an envelope or package addressed to the persons at the addresses on the attached service list and providing them to a professional messenger service for service. 22 I declare that I am employed in the office of a member of the Bar of this Court 23 at whose direction the service was made. I declare under penalty of perjury under 24 25 the laws of the United States of America that the above is true and correct. Executed on June 2, 2017, at Costa Mesa, California. 26 Diane Vo 27 Signature Type or Print Name ~1876677.DOCX 28 1 CERTIFICATE OF SERVICE

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