Matrix International Textile Inc v. Ross Stores Inc et al
Filing
23
PROTECTIVE ORDER by Magistrate Judge Alexander F. MacKinnon. Re Stipulation for Protective Order 21 . (ib)
1 John T. Egley, Bar No. 232545
2 jegley@calljensen.com
Scott P. Shaw, Bar No 223592
3 sshaw@calljensen.com
4 Samuel G. Brooks, Bar No. 272107
sbrooks@calljensen.com
5 W. Christopher Dalton, Bar No. 267697
6 cdalton@calljensen.com
CALL & JENSEN
7 A Professional Corporation
8 610 Newport Center Drive, Suite 700
Newport Beach, CA 92660
9 Tel: (949) 717-3000
10 Fax: (949) 717-3100
11 Attorneys for Defendant Meetu Magic, Inc.
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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17 MATRIX INTERNATIONAL TEXTILE,
18 INC., a California Corporation,
19
Case No. 2:17-cv-03415-JAK-AFM
[PROPOSED] PROTECTIVE ORDER
Plaintiff,
20
21
vs.
22 ROSS STORES, INC., a California
Corporation; ZERO II 60, INC. a Florida
23
Corporation; MEGA WEAR, INC., a New
24 York Corporation; MEETU MAGIC, INC.,
a New York Corporation; SUPERLINE,
25
INC., a California Corporation; and DOES
26 1 through 10,
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Defendants.
28
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On stipulation of the Parties, the Court enters a Protective Order in this matter as
follows:
1. 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 discovery and that the protection it
affords from public disclosure and use extends 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.
B.
GOOD CAUSE STATEMENT
This action is likely to involve trade secrets, customer and pricing lists and other
valuable research, development, commercial, financial, technical and/or proprietary
information for which special protection from public disclosure and from use for any
purpose other than prosecution of this action is warranted. Such confidential and
proprietary materials and information consist of, among other things, confidential
business or financial information, information regarding confidential business practices,
or other confidential research, development, or commercial information (including
information implicating privacy rights of third parties), information otherwise generally
unavailable to the public, or which may be privileged or otherwise protected from
disclosure under state or federal statutes, court rules, case decisions, or common law.
Accordingly, to expedite the flow of information, to facilitate the prompt resolution of
disputes over confidentiality of discovery materials, to adequately protect information
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the parties are entitled to keep confidential, to ensure that the parties are permitted
reasonable necessary uses of such material in preparation for and in the conduct of trial,
to address their handling at the end of the litigation, and 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.
C.
ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
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; Local Civil 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.
There is a strong presumption that the public has a right of access to judicial
proceedings and records in civil cases. In connection with non-dispositive motions,
good cause must be shown to support a filing under seal. See Kamakana v. City and
County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,
187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good
cause showing), and a specific showing of good cause or compelling reasons with
proper evidentiary support and legal justification, must be made with respect to
Protected Material that a party seeks to file under seal. The parties’ mere designation of
Disclosure or Discovery Material as CONFIDENTIAL does not—without the
submission of competent evidence by declaration, establishing that the material sought
to be filed under seal qualifies as confidential, privileged, or otherwise protectable—
constitute good cause.
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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 the relief
sought shall be narrowly tailored to serve the specific interest to be protected. See
Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
or type of information, document, or thing sought to be filed or introduced under seal in
connection with a dispositive motion or trial, the party seeking protection must
articulate compelling reasons, supported by specific facts and legal justification, for the
requested sealing order. Again, competent evidence supporting the application to file
documents under seal must be provided by declaration.
Any document that is not confidential, privileged, or otherwise protectable in its
entirety will not be filed under seal if the confidential portions can be redacted. If
documents can be redacted, then a redacted version for public viewing, omitting only
the confidential, privileged, or otherwise protectable portions of the document, shall be
filed. Any application that seeks to file documents under seal in their entirety should
include an explanation of why redaction is not feasible.
2. DEFINITIONS
2.1
Action: Matrix International Textile, Inc. v. Ross Stores, Inc., Case No.
2:17-cv-03415-JAK-AFM.
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
Counsel: Outside Counsel of Record and House Counsel (as well as their
support staff).
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2.5
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.”
2.6
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.
2.7
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.
2.8
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
Information or Items: extremely sensitive “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.
2.9
House Counsel: attorneys who are employees of a party to this Action.
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.
2.12 Party: any party to this Action, including all of its officers, directors,
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.
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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.
3. SCOPE
The protections conferred by this Stipulation and 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.
Any use of Protected Material at trial shall be governed by the orders of the trial
judge. This Order does not govern the use of Protected Material at trial.
4. DURATION
Once a case proceeds to trial, information that was designated as
CONFIDENTIAL or maintained pursuant to this protective order used or introduced as
an exhibit at trial 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, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing
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related documents are part of court record). Accordingly, the terms of this protective
order do not extend beyond the commencement of the trial.
5. DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection.
Each Party or Non-Party that designated information or items for protection under this
Order must take care to limit any such designation to specific material that 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.
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 (see, e.g., second paragraph of section 5.2(a) below), 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 or other pretrial or trial proceedings), that the
Producing Party affix at a minimum, the legend “CONFIDENTIAL” or “HIGHLY
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CONFIDENTIAL -- ATTORNEYS’ EYES ONLY” (hereinafter “CONFIDENTIAL”
legend or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES ONLY legend”), to
each page that contains protected material. If only a portion 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 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 legend,” or
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY legend” to each page that
contains Protected Material. If only a portion 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).
(b) for testimony given in depositions that the Designating Party identifies the
Disclosure or Discovery Material on the record, before the close of the deposition all
protected testimony.
(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
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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.
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.
6.3
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.
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. Such
Protected Material may be disclosed only to the categories of persons and under the
conditions described in this Order. When the 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.
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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 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 Action
to whom disclosure is reasonably necessary provided: (1) the deposing party requests
that the witness sign the form attached as Exhibit 1 hereto; 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 Stipulated 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 “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) 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) private court reporters and their staff to whom disclosure is reasonably
necessary for this Action and who have signed the “Acknowledgment and Agreement to
Be Bound” (Exhibit A);
(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);
(f) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information; and
(g) 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 other litigation that
compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES ONLY,”
that Party must:
(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 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 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.
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 NonParty in this Action and designated as “CONFIDENTIAL” or “HIGHLY
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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:
(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 NonParty;
(2) promptly provide the Non-Party with a copy of the Stipulated Protective
Order in this Action, the relevant discovery request(s), and a reasonably specific
description of the information requested; and
(3) make the information requested available for inspection by the Non-Party, if
requested.
(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.
10.
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
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Stipulated Protective Order, the Receiving Party must immediately (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” that is attached hereto as Exhibit A.
11.
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.
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
Stipulated 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.
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12.3 Filing Protected Material. A Party that seeks to file under seal any
Protected Material must comply with Local Civil Rule 79-5. Protected Material may
only be filed under seal pursuant to a court order authorizing the sealing of the specific
Protected Material at issue. 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.
13.
FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4, 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 (DURATION).
///
///
///
- 14 [PROPOSED] PROTECTIVE ORDER
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14.
VIOLATION
Any violation of this Order may be punished by appropriate measures including,
without limitation, contempt proceedings and/or monetary sanctions.
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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Dated: 9/13/2017
By:
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____________________________
Alexander F. MacKinnon
U.S. Magistrate Judge
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- 15 [PROPOSED] PROTECTIVE ORDER
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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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
______________, 2016 in the case of Matrix International Textile, Inc. v. Ross Stores,
Inc., et al., Case No.17-cv-03415-JAK-AFM. 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: _________________________________
City and State where sworn and signed: _________________________________
Printed name: ______________________________
Signature: _________________________________
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- 16 [PROPOSED] PROTECTIVE ORDER
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