Lovet Thomas v. FedEx Trade Networks Transport and Brokerage, Inc.

Filing 29

STIPULATED PROTECTIVE ORDER 28 by Magistrate Judge Steve Kim. (SEE ORDER FOR DETAILS). (clee)

1
2
3
4
5
6

Stephanie Stroup (SBN: 235071)
FEDERAL EXPRESS CORPORATION
2601 Main Street, Suite 340
Irvine, California 92614
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorney for Defendant, FEDEX TRADE
NETWORKS TRANSPORT &
BROKERAGE, INC.

7
8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

10
11

LOVET THOMAS, an individual,

12
13
14
15

v.

Plaintiff,

FEDEX TRADE NETWORKS
TRANSPORT & BROKERAGE,
INC. a New York Corporation; and
DOES 1 through 35, inclusive,

16

Defendants.

Case No. 2:17-cv-04156-TJH-SK
(Los Angeles County Superior Court Case
No. BC659611)
STIPULATED PROTECTIVE ORDER
Complaint Filed: April 28, 2017
Trial Date:
None

17
18
19
20
21
22
23
24
25
26
27
28
FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

1
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

1.

A. PURPOSES AND LIMITATIONS

2

Discovery in this action is likely to involve production of confidential,

3

proprietary, or private information for which special protection from public

4

disclosure and from use for any purpose other than prosecuting this litigation may

5

be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

6

enter the following Stipulated Protective Order. The parties acknowledge that this

7

Order does not confer blanket protections on all disclosures or responses to

8

discovery and that the protection it affords from public disclosure and use extends

9

only to the limited information or items that are entitled to confidential treatment

10

under the applicable legal principles. The parties further acknowledge, as set forth in

11

Section 12.3, below, that this Stipulated Protective Order does not entitle them to

12

file confidential information under seal; Civil Local Rule 79-5 sets forth the

13

procedures that must be followed and the standards that will be applied when a party

14

seeks permission from the court to file material under seal.

15

B. GOOD CAUSE STATEMENT

16

This action is likely to involve confidential business and personnel records,

17

as well as records reflecting confidential business practices and/or proprietary

18

information for which special protection from public disclosure and from use for

19

any purpose other than prosecution of this action is warranted. Such confidential

20

and proprietary materials and information consist of, among other things,

21

confidential business and personnel information (including from the personnel files

22

of third parties, implicating their privacy rights), and information regarding

23

confidential business practices, information otherwise generally unavailable to the

24

public, or which may be privileged or otherwise protected from disclosure under

25

state or federal statutes, court rules, case decisions, or common law. Accordingly,

26

to expedite the flow of information, to facilitate the prompt resolution of disputes

27

over confidentiality of discovery materials, to adequately protect information the

28

parties are entitled to keep confidential, to ensure that the parties are permitted

FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

2
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

reasonable necessary uses of such material in preparation for and in the conduct of

2

trial, to address their handling at the end of the litigation, and serve the ends of

3

justice, a protective order for such information is justified in this matter. It is the

4

intent of the parties that information

5

will not be designated as confidential for tactical reasons and that nothing be so

6

designated without a good faith belief that it has been maintained in a confidential,

7

non-public manner, and there is good cause why it should not be part of the public

8

record of this case.

9
10

2.

11
12

2.1

Action: Lovet Thomas v. Fedex Trade Networks Transport &

Brokerage, Inc., et al., Case No. 2:17-cv-TJH-SK.

13
14

DEFINITIONS

2.2

Challenging Party: a Party or Non-Party that challenges the

designation of information or items under this Order.

15

2.3

“CONFIDENTIAL” Information or Items: information (regardless of

16

how it is generated, stored or maintained) or tangible things that qualify for

17

protection under Federal Rule of Civil Procedure 26(c), and as specified above in

18

the Good Cause Statement.

19
20

2.4

Counsel: Outside Counsel of Record and House Counsel (as well as

their support staff).

21

2.5

Designating Party: a Party or Non-Party that designates information or

22

items that it produces in disclosures or in responses to discovery as

23

“CONFIDENTIAL.”

24

2.6

Disclosure or Discovery Material: all items or information, regardless

25

of the medium or manner in which it is generated, stored, or maintained (including,

26

among other things, testimony, transcripts, and tangible things), that are produced or

27

generated in disclosures or responses to discovery in this matter.

28
FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

3
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

2.7

1

Expert: a person with specialized knowledge or experience in a matter

2

pertinent to the litigation who has been retained by a Party or its counsel to serve as

3

an expert witness or as a consultant in this Action.
2.8

4
5
6

House Counsel does not include Outside Counsel of Record or any other outside
counsel.

7
8

House Counsel: attorneys who are employees of a party to this Action.

2.9

Non-Party: any natural person, partnership, corporation, association, or

other legal entity not named as a Party to this action.

9

2.10 Outside Counsel of Record: attorneys who are not employees of a

10

party to this Action but are retained to represent or advise a party to this Action and

11

have appeared in this Action on behalf of that party or are affiliated with a law firm

12

which has appeared on behalf of that party, and includes support staff.

13

2.11 Party: any party to this Action, including all of its officers, directors,

14

employees, consultants, retained experts, and Outside Counsel of Record (and their

15

support staffs).

16
17
18
19
20
21
22

2.12 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
2.13 Professional Vendors:

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.
2.14 Protected Material:

23
24

persons or entities that provide litigation

any Disclosure or Discovery Material that is

designated as “CONFIDENTIAL.”
2.15 Receiving Party:

25
26

Material from a Producing Party.

27

3.

a Party that receives Disclosure or Discovery

SCOPE

28
FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

4
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

The protections conferred by this Stipulation and Order cover not only

2

Protected Material (as defined above), but also (1) any information copied or

3

extracted from Protected Material; (2) all copies, excerpts, summaries, or

4

compilations of Protected Material; and (3) any testimony, conversations, or

5

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

6
7

trial judge. This Order does not govern the use of Protected Material at trial.

8
9

4.

10

DURATION
Even after final disposition of this litigation, the confidentiality obligations

11

imposed by this Order shall remain in effect until a Designating Party agrees

12

otherwise in writing or a court order otherwise directs. Final disposition shall be

13

deemed to be the later of (1) dismissal of all claims and defenses in this Action,

14

with or without prejudice; and (2) final judgment herein after the completion and

15

exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

16

including the time limits for filing any

17

motions or applications for extension of time pursuant to applicable law.

18

5.

19

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

20

Each Party or Non-Party that designates information or items for protection under

21

this Order must take care to limit any such designation to specific material that

22

qualifies under the appropriate standards. The Designating Party must designate for

23

protection only those parts of material, documents, items, or oral or written

24

communications that qualify so that other portions of the material, documents,

25

items, or communications for which protection is not warranted are not swept

26

unjustifiably within the ambit of this Order.

27
28
FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

Mass, indiscriminate, or routinized designations are prohibited. Designations
that are shown to be clearly unjustified or that have been made for an improper
5
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

purpose (e.g., to unnecessarily encumber the case development process or to impose

2

unnecessary expenses and burdens on other parties) may expose the Designating

3

Party to sanctions.

4

If it comes to a Designating Party’s attention that information or items that it

5

designated for protection do not qualify for protection, that Designating Party must

6

promptly notify all other Parties that it is withdrawing the inapplicable designation.
5.2

7

Manner and Timing of Designations. Except as otherwise provided in

8

this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

9

stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

10

under this Order must be clearly so designated before the material is disclosed or

11

produced.
Designation in conformity with this Order requires:

12

(a)

13

for information in documentary form (e.g., paper or electronic

14

documents, but excluding transcripts of depositions or other pretrial or trial

15

proceedings), that the Producing Party affix at a minimum, the legend

16

“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

17

contains protected material. If only a portion or portions of the material on a page

18

qualifies for protection, the Producing Party also must clearly identify the protected

19

portion(s) (e.g., by making appropriate markings in the margins).

20

A Party or Non-Party that makes original documents available for inspection

21

need not designate them for protection until after the inspecting Party has indicated

22

which documents it would like copied and produced. During the inspection and

23

before the designation, all of the material made available for inspection shall be

24

deemed “CONFIDENTIAL.” After the inspecting Party has identified the

25

documents it wants copied and produced, the Producing Party must determine which

26

documents, or portions thereof, qualify for protection under this Order. Then, before

27

producing the specified documents, the Producing Party must affix the

28

“CONFIDENTIAL legend” to each page that contains Protected Material. If only a

FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

6
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

portion or portions of the material on a page qualifies for protection, the Producing

2

Party also must clearly identify the protected portion(s) (e.g., by making appropriate

3

markings in the margins).

4

(b) for testimony given in depositions that the Designating Party identify

5

the Disclosure or Discovery Material on the record, before the close of the

6

deposition all protected testimony.

7

(c) for information produced in some form other than documentary and

8

for any other tangible items, that the Producing Party affix in a prominent place on

9

the exterior of the container or containers in which the information is stored the

10

legend “CONFIDENTIAL.” If only a portion or portions of the information

11

warrants protection, the Producing Party, to the extent practicable, shall identify the

12

protected portion(s).
5.3

13

Inadvertent Failures to Designate. If timely corrected, an inadvertent

14

failure to designate qualified information or items does not, standing alone, waive

15

the Designating Party’s right to secure protection under this Order for such material.

16

Upon timely correction of a designation, the Receiving Party must make reasonable

17

efforts to assure that the material is treated in accordance with the provisions of this

18

Order.

19

6.

20

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Timing of Challenges.

Any Party or Non-Party may challenge a

21

designation of confidentiality at any time that is consistent with the Court’s

22

Scheduling Order.

23
24

6.2

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq.

25

6.3

The burden of persuasion in any such challenge proceeding shall be on

26

the Designating Party. Frivolous challenges, and those made for an improper

27

purpose (e.g., to harass or impose unnecessary expenses and burdens on other

28

parties) may expose the Challenging Party to sanctions. Unless the Designating

FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

7
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

Party has waived or withdrawn the confidentiality designation, all parties shall

2

continue to afford the material in question the level of protection to which it is

3

entitled under the Producing Party’s designation until the Court rules on the

4

challenge.

5
6

7.

7

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material that is

8

disclosed or produced by another Party or by a Non-Party in connection with this

9

Action only for prosecuting, defending, or attempting to settle this Action. Such

10

Protected Material may be disclosed only to the categories of persons and under the

11

conditions described in this Order. When the Action has been terminated, a

12

Receiving Party must comply with the provisions of section 13 below (FINAL

13

DISPOSITION).

14

Protected Material must be stored and maintained by a Receiving Party at a

15

location and in a secure manner that ensures that access is limited to the persons

16

authorized under this Order.

17

7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

18

otherwise ordered by the court or permitted in writing by the Designating Party, a

19

Receiving

20

“CONFIDENTIAL” only to:

Party

may

disclose

any

information

or

item

designated

21

(a) the Receiving Party’s Outside Counsel of Record in this Action, as

22

well as employees of said Outside Counsel of Record to whom it is reasonably

23

necessary to disclose the information for this Action;

24
25

(b) the officers, directors, and employees (including House Counsel) of
the Receiving Party to whom disclosure is reasonably necessary for this Action;

26

(c) Experts (as defined in this Order) of the Receiving Party to whom

27

disclosure is reasonably necessary for this Action and who have signed the

28

“Acknowledgment and Agreement to Be Bound” (Exhibit A);

FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

8
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

(d) the court and its personnel;

2

(e) court reporters and their staff;

3

(f) professional jury or trial consultants, mock jurors, and Professional

4

Vendors to whom disclosure is reasonably necessary for this Action and who

5

have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

6

(g) the author or recipient of a document containing the information or a

7

custodian or other person who otherwise possessed or knew the information;

8

(h) during their depositions, witnesses ,and attorneys for witnesses, in the

9

Action to whom disclosure is reasonably necessary provided: (1) the deposing party

10

requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will

11

not be permitted to keep any confidential information unless they sign the

12

“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

13

agreed by the Designating Party or ordered by the court. Pages of transcribed

14

deposition testimony or exhibits to depositions that reveal Protected Material may

15

be separately bound by the court reporter and may not be disclosed to anyone except

16

as permitted under this Stipulated Protective Order; and

17
18

(i) any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by any of the parties engaged in settlement discussions.

19
20

8.

21

IN OTHER LITIGATION

22

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
If a Party is served with a subpoena or a court order issued in other litigation

23

that compels disclosure of any information or items designated in this Action as

24

“CONFIDENTIAL,” that Party must:

25
26

(a) promptly notify in writing the Designating Party. Such
notification shall include a copy of the subpoena or court order;

27
28
FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

(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
9
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

the subpoena or order is subject to this Protective Order. Such notification shall

2

include a copy of this Stipulated Protective Order; and
(c)

3
4

cooperate with respect to all reasonable procedures sought to

be pursued by the Designating Party whose Protected Material may be affected.

5

If the Designating Party timely seeks a protective order, the Party served with

6

the subpoena or court order shall not produce any information designated in this

7

action as “CONFIDENTIAL” before a determination by the court from which the

8

subpoena or order issued, unless the Party has obtained the Designating Party’s

9

permission. The Designating Party shall bear the burden and expense of seeking

10

protection in that court of its confidential material and nothing in these provisions

11

should be construed as authorizing or encouraging a Receiving Party in this Action

12

to disobey a lawful directive from another court.

13
14

9.

A

NON-PARTY’S

PROTECTED

15

MATERIAL

SOUGHT

TO

BE

PRODUCED IN THIS LITIGATION

16

(a) The terms of this Order are applicable to information produced by a

17

Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

18

produced by Non-Parties in connection with this litigation is protected by the

19

remedies and relief provided by this Order. Nothing in these provisions should be

20

construed as prohibiting a Non-Party from seeking additional protections.

21

(b) In the event that a Party is required, by a valid discovery request, to

22

produce a Non-Party’s confidential information in its possession, and the Party is

23

subject to an agreement with the Non-Party not to produce the Non-Party’s

24

confidential information, then the Party shall:

25

(1) promptly notify in writing the Requesting Party and the Non-Party

26

that some or all of the information requested is subject to a confidentiality

27

agreement with a Non-Party;

28
FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

10
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

(2) promptly provide the Non-Party with a copy of the Stipulated

2

Protective Order in this Action, the relevant discovery request(s), and a reasonably

3

specific description of the information requested; and
(3) make the information requested available for inspection by the

4
5

Non-Party, if requested.

6

(c) If the Non-Party fails to seek a protective order from this court within

7

14 days of receiving the notice and accompanying information, the Receiving Party

8

may produce the Non-Party’s confidential information responsive to the discovery

9

request. If the Non-Party timely seeks a protective order, the Receiving Party shall

10

not produce any information in its possession or control that is subject to the

11

confidentiality agreement with the Non-Party before a determination by the court.

12

Absent a court order to the contrary, the Non-Party shall bear the burden and

13

expense of seeking protection in this court of its Protected Material.

14
15

10.

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
25

11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

26

PROTECTED MATERIAL

27

When a Producing Party gives notice to Receiving Parties that certain

28

inadvertently produced material is subject to a claim of privilege or other protection,

FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

11
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

2

Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

3

may be established in an e-discovery order that provides for production without

4

prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar

5

as the parties reach an agreement on the effect of disclosure of a communication or

6

information covered by the attorney-client privilege or work product protection, the

7

parties may incorporate their agreement in the stipulated protective order submitted

8

to the court.

9
10

12.

11
12

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.

13
14
15
16
17

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.

18
19
20
21
22
23
24
25
26
27
28
FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

MISCELLANEOUS

12.3 Filing Protected Material. A Party that seeks to file under seal any
Protected Material must comply with Civil Local 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
12
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

all Protected Material to the Producing Party or destroy such material. As used in

2

this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

3

summaries, and any other format reproducing or capturing any of the Protected

4

Material. Whether the Protected Material is returned or destroyed, the Receiving

5

Party must submit a written certification to the Producing Party (and, if not the same

6

person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

7

(by category, where appropriate) all the Protected Material that was returned or

8

destroyed and (2)affirms that the Receiving Party has not retained any copies,

9

abstracts, compilations, summaries or any other format reproducing or capturing any

10

of the Protected Material. Notwithstanding this provision, Counsel are entitled to

11

retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

12

transcripts, legal memoranda, discovery, correspondence, deposition and trial

13

exhibits, expert reports, attorney work product, and consultant and expert work

14

product, even if such materials contain Protected Material. Any such archival

15

copies that contain or constitute Protected Material remain subject to this Protective

16

Order as set forth in

17

Section 4 (DURATION).

18
19
20
21

14.

Any violation of this Order may be punished by any and all appropriate

measures including, without limitation, contempt proceedings and/or monetary
sanctions.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

22
23
24

DATED: June 4, 2018

25

KESLUK, SILVERSTEIN & JACOB, PC
By: /s/Mia Munro
Mia Munro, Esq.
Attorney for Plaintiff, LOVET THOMAS

26
27
28
FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

13
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

DATED: June 4, 2018

FEDERAL EXPRESS CORPORATION

2

By:/s/ Stephanie Stroup
Stephanie Stroup
Attorney for Defendant, FEDEX TRADE
NETWORKS TRANSPORT & BROKERAGE,
INC.

3
4
5
6
7

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

8
9

DATED: June 6, 2018

10

_________________________
Honorable Steve Kim
United States Magistrate Judge

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

14
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER

1

EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

2
3

I, _____________________________ [print

4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

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 ______________ Lovet Thomas v. Fedex Trade Networks
Transport & Brokerage, Inc. et al., Case No. 2:17-cv-04156-TJH-SK. 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 the purpose of enforcing the terms of this
Stipulated Protective Order, even if such enforcement proceedings occur after
termination of this action. I hereby appoint
or type full name] of

[print
[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: __________________________________

28
FEDERAL EXPRESS
CORPORATION
2601 MAIN STREET
SUITE 340
IRVINE, CA 92614

15
1281695

Case No. 2:17-cv-04156-TJH-SK
STIPULATED PROTECTIVE ORDER