Casey Thornton et al v. Micro Star International Co. Ltd. et al

Filing 45

PROTECTIVE ORDER by Magistrate Judge Alexander F. MacKinnon re Stipulation for Protective Order 44 . (ib)

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1 2 3 4 5 6 7 8 9 10 WESTERMAN LAW CORP. Jeff S. Westerman (SBN 94559) Ken A. Remson (SBN153850) 1875 Century Park East, Suite 2200 Los Angeles, CA 90067 Tel: (310) 698-7880 Fax: (310) 698-7452 THE CONSUMER LAW GROUP Alan M. Mansfield (SBN 125998) 16870 W. Bernardo Dr., Suite 400 San Diego, CA 92127 Tel: (619) 308-5034 Fax (855) 274-1888 Attorneys for Plaintiffs 11 UNITED STATES DISTRICT COURT 12 CENTRAL DISTRICT OF CALIFORNIA 13 CASEY THORNTON and CARL JONES, individually and on behalf of 14 all others similarly situated, CASE NO. 17-cv-03231-CAS (AFM) 15 STIPULATED PROTECTIVE ORDER1 Plaintiffs, 16 CLASS ACTION v. 17 MSI COMPUTER CORP.; and DOES 1-10, 18 Defendants. 19 20 1. 21 22 23 24 25 26 27 28 A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, proprietary or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to This Stipulated Protective Order is based substantially on the model protective order provided under Magistrate Judge Alexander F. MacKinnon’s Procedures. 1 -1STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 discovery and that the protection it affords from public disclosure and use extends 2 only to the limited information or items that are entitled to confidential treatment 3 under the applicable legal principles. 4 B. 5 This action is likely to involve trade secrets, customer and pricing lists and 6 other valuable research, development, commercial, financial, technical and/or 7 proprietary information for which special protection from public disclosure and 8 from use for any purpose other than prosecution of this action is warranted. Such 9 confidential and proprietary materials and information consist of, among 10 other things, confidential business or financial information, information regarding 11 confidential business practices, or other confidential research, development, 12 or commercial information (including information implicating privacy rights of 13 third parties), information otherwise generally unavailable to the public, or which 14 may be privileged or otherwise protected from disclosure under state or federal 15 statutes, court rules, case decisions, or common law. Accordingly, to expedite 16 the flow of information, to facilitate the prompt resolution of disputes over 17 confidentiality of discovery materials, to adequately protect information the parties 18 are entitled to keep confidential, to ensure that the parties are permitted 19 reasonable necessary uses of such material in preparation for and in the conduct 20 of trial, to address their handling at the end of the litigation, and serve the ends of 21 justice, a protective order for such information is justified in this matter. It is the 22 intent of the parties that information will not be designated as confidential for 23 tactical reasons and that nothing be so designated without a good faith belief 24 that it has been maintained in a confidential, non-public manner, and there is good 25 cause why it should not be part of the public record of this case. 26 27 28 C. GOOD CAUSE STATEMENT ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL The parties further acknowledge, as set forth in Section 12.3, below, that -2STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 this Stipulated Protective Order does not entitle them to file confidential 2 information under seal; Local Civil Rule 79-5 sets forth the procedures that must 3 be followed and the standards that will be applied when a party seeks permission 4 from the court to file material under seal. 5 There is a strong presumption that the public has a right of access to 6 judicial proceedings and records in civil cases. In connection with non-dispositive 7 motions, good cause must be shown to support a filing under seal. See Kamakana 8 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. 9 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. 10 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 11 protective orders require good cause showing), and a specific showing of good 12 cause or compelling reasons with proper evidentiary support and legal 13 justification, must be made with respect to Protected Material that a party seeks to 14 file under seal. 15 Material as CONFIDENTIAL does not—without the submission of competent 16 evidence by declaration, establishing that the material sought to be filed under 17 seal qualifies as confidential, privileged, or otherwise protectable—constitute 18 good cause. The parties’ mere designation of Disclosure or Discovery 19 Further, if a party requests sealing related to a dispositive motion or trial, 20 then compelling reasons, not only good cause, for the sealing must be shown, 21 and the relief sought shall be narrowly tailored to serve the specific interest to be 22 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 23 2010). For each item or type of information, document, or thing sought to be filed 24 or introduced under seal in connection with a dispositive motion or trial, the 25 party seeking protection must articulate compelling reasons, supported by specific 26 facts and legal justification, for the requested sealing order. Again, competent 27 evidence supporting the application to file documents under seal must be provided 28 by declaration. -3STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 Any document that is not confidential, privileged, or otherwise protectable 2 in its entirety will not be filed under seal if the confidential portions can be 3 redacted. 4 viewing, omitting only the confidential, privileged, or otherwise protectable 5 portions of the document, shall be filed. Any application that seeks to file 6 documents under seal in their entirety should include an explanation of why 7 redaction is not feasible. 8 2. If documents can be redacted, then a redacted version for public DEFINITIONS 9 2.1 Action: this pending federal lawsuit. 10 2.2 Challenging Party: a Party or Non-Party that challenges the 11 12 designation of information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless 13 of how it is generated, stored or maintained) or tangible things that qualify 14 for protection under Federal Rule of Civil Procedure 26(c), and as specified 15 above in the Good Cause Statement. 16 17 18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 2.5 Designating Party: a Party or Non-Party that designates information 19 or items that it produces in disclosures or in responses to discovery as 20 “CONFIDENTIAL.” 21 2.6 Disclosure or Discovery Material: all items or information, 22 regardless of the medium or manner in which it is generated, stored, or maintained 23 (including, among other things, testimony, transcripts, and tangible things), that are 24 produced or generated in disclosures or responses to discovery in this matter. 25 2.7 Expert: a person with specialized knowledge or experience in a 26 matter pertinent to the litigation who has been retained by a Party or its counsel to 27 serve as an expert witness or as a consultant in this Action. 28 2.8 House Counsel: attorneys who are employees of a party to this -4- STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 Action. House Counsel does not include Outside Counsel of Record or any 2 other outside counsel. 2.9 3 4 Non-Party: any natural person, partnership, corporation, association or other legal entity not named as a Party to this action. 2.10 5 Outside Counsel of Record: attorneys who are not employees of 6 a party to this Action but are retained to represent or advise a party to this Action 7 and have appeared in this Action on behalf of that party or are affiliated with a law 8 firm that has appeared on behalf of that party, and includes support staff. 2.11 9 Party: any party to this Action, including all of its officers, 10 directors, employees, consultants, retained experts, and Outside Counsel of 11 Record (and their support staffs). 2.12 12 13 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 2.13 14 Professional Vendors: persons or entities that provide 15 litigation support services (e.g., photocopying, videotaping, translating, preparing 16 exhibits or demonstrations, and organizing, storing, or retrieving data in any form 17 or medium) and their employees and subcontractors. 2.14 18 19 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 2.15 20 Receiving Party: a Party that receives Disclosure or Discovery 21 Material from a Producing Party. 22 3. SCOPE 23 The protections conferred by this Stipulation and Order cover not 24 only Protected Material (as defined above), but also (1) any information 25 copied or extracted from Protected Material; (2) all copies, excerpts, summaries, 26 or compilations of Protected Material; and (3) any testimony, conversations, 27 or presentations by Parties or their Counsel that might reveal Protected Material. 28 Any use of Protected Material at trial shall be governed by the orders of -5STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 the trial judge. This Order does not govern the use of Protected Material at trial. 2 4. DURATION 3 Once a case proceeds to trial, information that was designated as 4 CONFIDENTIAL or maintained pursuant to this protective order used or 5 introduced as an exhibit at trial becomes public and will be presumptively 6 available to all members of the public, including the press, unless compelling 7 reasons supported by specific factual findings to proceed otherwise are made to the 8 trial judge in advance of the trial. 9 (distinguishing “good cause” showing for sealing documents produced in 10 discovery from “compelling reasons” standard when merits-related documents are 11 part of court record). Accordingly, the terms of this protective order do not extend 12 beyond the commencement of the trial. 13 5. 14 See Kamakana, 447 F.3d at 1180-81 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for 15 Protection. Each Party or Non-Party that designates information or items for 16 protection under this Order must take care to limit any such designation to 17 specific material that qualifies under the appropriate standards. The Designating 18 Party must designate for protection only those parts of material, documents, 19 items or oral or written communications that qualify so that other portions of 20 the material, documents, items or communications for which protection is not 21 warranted are not swept unjustifiably within the ambit of this Order. 22 Mass, indiscriminate or routinized designations are prohibited. 23 Designations that are shown to be clearly unjustified or that have been made 24 for an improper purpose (e.g., to unnecessarily encumber the case development 25 process or to impose unnecessary expenses and burdens on other parties) may 26 expose the Designating Party to sanctions. 27 If it comes to a Designating Party’s attention that information or items that 28 it designated for protection do not qualify for protection, that Designating Party -6STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 must promptly notify all other Parties that it is withdrawing the inapplicable 2 designation. 3 5.2 Manner and Timing of Designations. Except as otherwise provided 4 in this Order (see, e.g., second paragraph of section 5.2(a) below), or as 5 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies 6 for protection under this Order must be clearly so designated before the material 7 is disclosed or produced. 8 9 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or 10 electronic documents, but excluding transcripts of depositions or other pretrial 11 or trial proceedings), that the Producing Party affix at minimum, the legend 12 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 13 contains protected material. If only a portion of the material on a page qualifies for 14 protection, the Producing Party also must clearly identify the protected portion(s) 15 (e.g., by making appropriate markings in the margins). 16 A Party or Non-Party that makes original documents available for inspection 17 need not designate them for protection until after the inspecting Party has indicated 18 which documents it would like copied and produced. During the inspection and 19 before the designation, all of the material made available for inspection shall be 20 deemed “CONFIDENTIAL.” After the inspecting Party has 21 documents it wants copied and produced, the Producing Party must determine 22 which documents, or portions thereof, qualify for protection under this Order. 23 Then, before producing the specified documents, the Producing Party must 24 affix the “CONFIDENTIAL legend” to each page that contains Protected Material. 25 If only a portion of the material on a page qualifies for protection, the Producing 26 Party also must clearly identify the protected portion(s) (e.g., by making 27 appropriate markings in the margins). 28 (b) identified the for testimony given in depositions that the Designating Party -7- STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 identifies the Disclosure or Discovery Material on the record, before the 2 close of the deposition all protected testimony. (c) 3 for information produced in some form other than 4 documentary and for any other tangible items, that the Producing Party affix in a 5 prominent place on the exterior of the container or containers in which the 6 information is stored the legend “CONFIDENTIAL.” 7 portions of the information warrants protection, the Producing Party, to the extent 8 practicable, shall identify the protected portion(s). 5.3 9 Inadvertent Failures to Designate. If only a portion or If timely corrected, an 10 inadvertent failure to designate qualified information or items does not, standing 11 alone, waive the Designating Party’s right to secure protection under this Order for 12 such material. Upon timely correction of a designation, the Receiving Party must 13 make reasonable efforts to assure that the material is treated in accordance with the 14 provisions of this Order. 15 6. 16 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 17 designation of confidentiality at any time that is consistent with the 18 Court’s Scheduling Order. 19 20 21 22 23 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37-1, et seq. 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint stipulation pursuant to Local Rule 37-2. 6.4 The burden of persuasion in any such challenge proceeding shall be 24 on the Designating Party. Frivolous challenges, and those made for an 25 improper purpose (e.g., to harass or impose unnecessary expenses and 26 burdens on other parties) may expose the Challenging Party to sanctions. 27 Unless the Designating Party has waived or withdrawn the confidentiality 28 designation, all parties shall continue to afford the material in question the -8STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 level of protection to which it is entitled 2 designation until the Court rules on the challenge. 3 7. 4 under the Producing Party’s ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that 5 is disclosed or produced by another Party or by a Non-Party in connection with 6 this Action only for prosecuting, defending or attempting to settle this Action. 7 Such Protected Material may be disclosed only to the categories of persons and 8 under the conditions described in this Order. When the Action has been 9 terminated, a Receiving Party must comply with the provisions of section 13 10 below (FINAL DISPOSITION). 11 Protected Material must be stored and maintained by a Receiving Party at 12 a location and in a secure manner that ensures that access is limited to the 13 persons 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 17 “CONFIDENTIAL” only to: 18 (a) Party may disclose any information or item designated the Receiving Party’s Outside Counsel of Record in this 19 Action, as well as employees of said Outside Counsel of Record to whom it is 20 reasonably necessary to disclose the information for this Action; (b) 21 the officers, directors, and employees (including House 22 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this 23 Action; 24 (c) Experts (as defined in this Order) of the Receiving Party to 25 whom disclosure is reasonably necessary for this Action and who have 26 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) the court and its personnel; 28 (e) court reporters and their staff; -9- STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) (f) 1 professional jury or trial consultants, mock jurors, and 2 Professional Vendors to whom disclosure is reasonably necessary for this Action 3 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 4 A); (g) 5 the author or recipient of a document containing the 6 information or a custodian or other person who otherwise possessed or knew the 7 information; (h) 8 during their depositions, witnesses, and attorneys for witnesses, 9 in the Action to whom disclosure is reasonably necessary provided: (1) the 10 deposing party requests that the witness sign the form attached as Exhibit 1 hereto; 11 and (2) they will not be permitted to keep any confidential information 12 unless 13 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by 14 the court. Pages of transcribed deposition testimony or exhibits to depositions 15 that reveal Protected Material may be separately bound by the court reporter and 16 may not be disclosed to anyone except as permitted under this Stipulated Protective 17 Order; and they (i) 18 sign the “Acknowledgment and Agreement to Be Bound” any mediator or settlement officer, and their supporting 19 personnel, mutually agreed upon by any of the parties engaged in settlement 20 discussions. 21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 22 IN OTHER LITIGATION 23 If a Party is served with a subpoena or a court order issued in other litigation 24 that compels disclosure of any information or items designated in this Action as 25 “CONFIDENTIAL,” that Party must: 26 27 28 (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 -10- STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 order to issue in the other litigation that some or all of the material covered 2 by the subpoena or order is subject to this Protective Order. Such notification shall 3 include a copy of this Stipulated Protective Order; and (c) 4 5 cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 6 If the Designating Party timely seeks a protective order, the Party served with 7 the subpoena or court order shall not produce any information designated in this 8 action as “CONFIDENTIAL” before a determination by the court from which the 9 subpoena or order issued, unless the Party has obtained the Designating Party’s 10 permission. The Designating Party shall bear the burden and expense of seeking 11 protection in that court of its confidential material and nothing in these provisions 12 should be construed as authorizing or encouraging a Receiving Party in this Action 13 to disobey a lawful directive from another court. 14 9. 15 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION (a) 16 The terms of this Order are applicable to information produced 17 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 18 information produced by Non-Parties in connection with this litigation is 19 protected by the remedies and relief provided by this Order. Nothing in these 20 provisions should be construed as prohibiting a Non-Party from seeking additional 21 protections. 22 (b) In the event that a Party is required, by a valid discovery 23 request, to produce a Non-Party’s confidential information in its possession, and 24 the Party is subject to an agreement with the Non-Party not to produce the 25 Non-Party’s confidential information, then the Party shall: 26 (1) promptly notify in writing the Requesting Party and the 27 Non-Party that some or all of the information requested is subject to a 28 confidentiality agreement with a Non-Party; -11STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) (2) 1 promptly provide the Non-Party with a copy of the 2 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 3 reasonably specific description of the information requested; and (3) 4 5 make the information requested available for inspection by the Non-Party, if requested. (c) 6 If the Non-Party fails to seek a protective order from this court 7 within 14 days of receiving the notice and accompanying information, the 8 Receiving Party 9 responsive to the discovery request. If the Non-Party timely seeks a protective 10 order, the Receiving Party shall not produce any information in its possession 11 or control that is subject to the confidentiality agreement with the Non-Party 12 before a determination by the court. Absent a court order to the contrary, the 13 Non-Party shall bear the burden and expense of seeking protection in this court of 14 its Protected Material. 15 10. may produce the Non-Party’s confidential information UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 16 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 17 Protected Material to any person or in any circumstance not authorized under this 18 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 19 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 20 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 21 persons to whom unauthorized disclosures were made of all the terms of this Order, 22 and (d) request such person or persons to execute the “Acknowledgment and 23 Agreement to Be Bound” that is attached hereto as Exhibit A. 24 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 25 PROTECTED MATERIAL 26 When a Producing Party gives notice to Receiving Parties that certain 27 inadvertently produced material is subject to a claim of privilege or other protection, 28 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil -12STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 2 procedure may be established in an e-discovery order that provides for production 3 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 4 (e), insofar as the parties reach an agreement on the effect of disclosure of a 5 communication or information covered by the attorney-client privilege or work 6 product protection, the parties may incorporate their agreement in the stipulated 7 protective order submitted to the court. 8 12. 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 9 10 MISCELLANEOUS person to seek its modification by the Court in the future. 11 12.2 Right to Assert Other Objections. By stipulating to the entry of this 12 Protective Order, no Party waives any right it otherwise would have to object to 13 disclosing or producing any information or item on any ground not addressed in this 14 Stipulated Protective Order. Similarly, no Party waives any right to object on any 15 ground to use in evidence of any of the material covered by this Protective Order. 16 12.3 Filing Protected Material. A Party that seeks to file under seal any 17 Protected Material must comply with Local Civil Rule 79-5. Protected Material 18 may only be filed under seal pursuant to a court order authorizing the sealing of the 19 specific Protected Material at issue. If a Party’s request to file Protected Material 20 under seal is denied by the court, then the Receiving Party may file the information 21 in the public record unless otherwise instructed by the court. 22 13. FINAL DISPOSITION 23 After the final disposition of this Action, as defined in paragraph 4, within 60 24 days of a written request by the Designating Party, each Receiving Party must return 25 all Protected Material to the Producing Party or destroy such material. As used in 26 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 27 summaries, and any other format reproducing or capturing any of the Protected 28 Material. Whether the Protected Material is returned or destroyed, the Receiving -13STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 Party must submit a written certification to the Producing Party (and, if not the same 2 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 3 (by category, where appropriate) all the Protected Material that was returned or 4 destroyed and (2) affirms that the Receiving Party has not retained any copies, 5 abstracts, compilations, summaries or any other format reproducing or capturing any 6 of the Protected Material. Notwithstanding this provision, Counsel are entitled 7 to retain an archival copy of all pleadings, motion papers, trial, deposition, and 8 hearing transcripts, legal memoranda, correspondence, deposition and trial 9 exhibits, expert reports, attorney work product, and consultant and expert work 10 product, even if such materials contain Protected Material. Any such archival 11 copies that contain or constitute Protected Material remain subject to this 12 Protective Order as set forth in Section 4 (DURATION). 13 14. 14 VIOLATION Any violation of this Order may be punished by appropriate measures 15 including, without limitation, contempt proceedings and/or monetary sanctions. 16 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 17 DATED: November 30, 2017 18 WESTERMAN LAW CORP. 19 By: /s/ Jeff S. Westerman Jeff S. Westerman (SBN 94559) Ken A. Remson (SBN 153850) 1875 Century Park East, Suite 2200 Los Angeles, CA 90067 Tel: (310) 698-7880 / Fax: (310) 698-7452 20 21 22 23 24 THE CONSUMER LAW GROUP 27 By: /s/ Alan M. Mansfield Alan M. Mansfield (SBN 125998) 16870 W. Bernardo Dr., Suite 400 San Diego, CA 92127 Tel: (619) 308-5034 / Fax (855) 274-1888 28 Attorneys for Plaintiffs 25 26 -14STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 DATED: November 30, 2017 2 WHITE & CASE LLP 3 7 By: /s/ Bryan A. Merryman Bryan a. Merryman 9SBN 134347) Deema B. Abini (SBN 301481) 555 S. Flower Street, Suite 2700 Los Angeles, CA 90071-2433 Tel: (213) 620-7700 Fax: (213) 452-2329 8 Attorneys for Defendant 4 5 6 9 10 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 11 12 DATED: 12/1/2017 13 14 15 16 ALEXANDER F. MacKINNON United States Magistrate Judge 17 18 19 20 21 22 23 24 25 26 27 28 -15STIPULATED PROTECTIVE ORDER CASE NO. 17-CV-03231-CAS (AFM) 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND I, 3 [print or type full name], of [print 4 or type full address], declare under penalty of perjury that I have read in its entirety 5 and understand the Stipulated Protective Order that was issued by the United States 6 District Court for the Central District of California on [date] in the case of Thornton, 7 et al. v. MSI Computer Corp., et al., Case No. 2:17-cv-03231-CAS (AFM). 8 agree to comply with and to be bound by all the terms of this Stipulated Protective 9 Order and I understand and acknowledge that failure to so comply could expose me I 10 to sanctions and punishment in the nature of contempt. I solemnly promise that I 11 will not disclose in any manner any information or item that is subject to this 12 Stipulated Protective Order to any person or entity except in strict compliance with 13 the provisions of this Order. I further agree to submit to the jurisdiction of the 14 United States District Court for the Central District of California for enforcing the 15 terms of this Stipulated Protective Order, even if such enforcement proceedings 16 occur after termination of this action. I hereby appoint 17 type full name] of 18 telephone number] as my California agent for service of process in connection with 19 this action or any proceedings related to enforcement of this Stipulated Protective 20 Order. 21 Date: 22 City and State where sworn and signed: 23 Printed name: [print [print or type full address and 24 25 Signature: 26 27 28 -16STIPULATED PROTECTIVE ORDER or CASE NO. 17-CV-03231-CAS (AFM)

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