World Cleaners, Inc. v. Central National Insurance Company of Omaha

Filing 82

STIPULATED PROTECTIVE ORDER by Magistrate Judge Rozella A. Oliver re Joint Stipulation re Discovery Motion, 80 . See order for details. (hr)

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Gary R. Selvin, State Bar No. 112030
E-mail:
[e-mail]
John A. Chatowski, State Bar No. 174471
E-mail:
[e-mail]
SELVIN WRAITH HALMAN LLP
505 14th Street, Suite 1200
Oakland, CA 94612
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant and Counter-Complainant
OAKWOOD INSURANCE COMPANY
[LIST OF ALL PARTIES AND
COUNSEL ON NEXT PAGE]

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IN THE UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION

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14 WORLD CLEANERS, INC., a
California corporation,
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Plaintiff,
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v.
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CASE NO. 2:17-cv-04731-DSF-RAO
[PROPOSED] STIPULATED
PROTECTIVE ORDER

18 CENTRAL NATIONAL INSURANCE
COMPANY OF OMAHA, now known
19 as OAKWOOD INSURANCE
20 COMPANY,
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Defendant.

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AND RELATED COUNTERCLAIM
23 AND THIRD PARTY COMPLAINT
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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DAVID R. ISOLA, ESQ. SBN 150311
E-mail: [e-mail]
ISOLA LAW GROUP, LLP
405 West Pine Street
Lodi, California 95240
Telephone: [phone]
Attorneys for Plaintiff and Counter-Defendant,
WORLD CLEANERS, INC. and
Third Party Defendant,
538 W. 5th STREET, SAN PEDRO, INC.
GARY R. SELVIN, SBN 112030
E-mail: [e-mail]
JOHN A. CHATOWSKI, SBN 174471
E-mail: [e-mail]
SELVIN WRAITH HALMAN LLP
505 14th Street, Suite 1200
Oakland, CA 94612
Telephone: [phone]
Attorneys for Defendant, Counter-Complainant,
and Third Party Plaintiff
OAKWOOD INSURANCE COMPANY

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Philip E. Smith (SBN 117710)
E-mail: [e-mail]
Michael W. Ellison (SBN 1458342)
E-mail: [e-mail]
SMITH ♦ ELLISON
18881 Von Karman Avenue, Suite 960
Irvine, California 92612
Telephone: [phone]
Facsimile: [phone]
Attorneys for Third Party Defendant
HARTFORD FIRE INSURANCE COMPANY

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[PROPOSED] STIPULATED PROTECTIVE ORDER

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Pursuant to United Sates Magistrate Judge Rozella A. Oliver’s Standing

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Protective Order, the following provisions shall apply to the disclosure and protection

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of confidential, proprietary and private information in this action:

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A.

PURPOSES AND LIMITATIONS

The parties have indicated that discovery in this action is likely to involve

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production of confidential, proprietary or private information for which special

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protection from public disclosure and from use for any purpose other than prosecuting

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this litigation may be warranted. This Order does not confer blanket protections on all

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disclosures or responses to discovery and the protection it affords from public

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disclosure and use extends only to the limited information or items that are entitled to

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confidential treatment under the applicable legal principles.

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B.

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The parties have indicated that this action is likely to involve trade secrets,

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customer and pricing lists and other valuable research, development, commercial,

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financial, technical and/or proprietary information for which special protection from

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public disclosure and from use for any purpose other than prosecution of this action is

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warranted. Such confidential and proprietary materials and information consist of,

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among other things, confidential business or financial information, information

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regarding confidential business practices, or other confidential research, development,

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or commercial information (including information implicating privacy rights of third

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parties), information otherwise generally unavailable to the public, or which may be

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privileged or otherwise protected from disclosure under state or federal statutes, court

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rules, case decisions, or common law. Accordingly, to expedite the flow of

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information, to facilitate the prompt resolution of disputes over confidentiality of

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discovery materials, to adequately protect information the parties are entitled to keep

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confidential, to ensure that the parties are permitted reasonable necessary uses of such

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material in preparation for and in the conduct of trial, to address their handling at the

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end of the litigation, and serve the ends of justice, a protective order for such
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

GOOD CAUSE STATEMENT

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information is justified in this matter. It is the intent of the parties that information will

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

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without a good faith belief that it has been maintained in a confidential, non-public

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

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case.

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C.

PROCEDURE FOR FILING UNDER SEAL

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The parties acknowledge, as set forth in Section 12.3, below, that this Stipulated

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Protective Order does not entitle them to file confidential information under seal;

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Local Civil Rule 79-5 sets forth the procedures that must be followed and the standards

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that will be applied when a party seeks permission from the court to file material under

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seal.

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There is a strong presumption that the public has a right of access to judicial

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proceedings and records in civil cases. In connection with non-dispositive motions,

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good cause must be shown to support a filing under seal. See Kamakana v. City and

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County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors

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Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,

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187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good

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cause showing), and a specific showing of good cause or compelling reasons with

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proper evidentiary support and legal justification, must be made with respect to

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Protected Material that a party seeks to file under seal. The parties’ mere designation

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of Disclosure or Discovery Material as "CONFIDENTIAL" does not— without the

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submission of competent evidence by declaration, establishing that the material sought

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to be filed under seal qualifies as confidential, privileged, or otherwise protectable—

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constitute good cause.

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Further, if a party requests sealing related to a dispositive motion or trial, then

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compelling reasons, not only good cause, for the sealing must be shown, and the relief

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sought shall be narrowly tailored to serve the specific interest to be protected. See

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Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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or type of information, document, or thing sought to be filed or introduced under seal

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in connection with a dispositive motion or trial, the party seeking protection must

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articulate compelling reasons, supported by specific facts and legal justification, for the

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requested sealing order. Again, competent evidence supporting the application to file

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documents under seal must be provided by declaration.

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Any document that is not confidential, privileged, or otherwise protectable in its

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entirety will not be filed under seal if the confidential portions can be redacted. If

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documents can be redacted, then a redacted version for public viewing, omitting only

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the confidential, privileged, or otherwise protectable portions of the document, shall be

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filed. Any application that seeks to file documents under seal in their entirety should

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include an explanation of why redaction is not feasible.
ACCORDINGLY, IN LIGHT OF THE FOREGOING, THE PARTIES

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HEREBY STIPULATE AND AGREE AS FOLLOWS:

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2.

DEFINITIONS

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2.1

Action: This pending lawsuit.

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2.2

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

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information or items under this Order.
2.3

“CONFIDENTIAL” Information or Items: information (regardless of how

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

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

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Statement.

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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 or

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

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“CONFIDENTIAL.”

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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,
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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

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generated in disclosures or responses to discovery in this matter.

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2.7

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

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

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expert witness or as a consultant in this Action. This definition includes a professional

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jury or trial consultant retained in connection with this litigation.

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2.8

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

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

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counsel.

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2.9

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

other legal entity not named as a Party to this action.
2.10 Outside Counsel of Record: attorneys who are not employees of a party to

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

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

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

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

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

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support staffs).

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

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services (e.g., photocopying, videotaping, translating, preparing exhibits or

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demonstrations, and organizing, storing, or retrieving data in any form or medium) and

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their employees and subcontractors.

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2.14 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
from a Producing Party.
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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3.

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SCOPE
The protections conferred by this Stipulation and Order cover not only Protected

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

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Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

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Material; and (3) any testimony, conversations, or presentations by Parties or their

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Counsel that might reveal Protected Material.

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Any use of Protected Material at trial shall be governed by the orders of the trial

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

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4.

DURATION

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Even after the termination of this litigation, the confidentiality obligations

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

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in writing or a court order otherwise directs.

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DESIGNATING PROTECTED MATERIAL

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5.1

Exercise of Restraint and Care in Designating Material for Protection.

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

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

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

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only those parts of material, documents, items or oral or written communications that

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qualify so that other portions of the material, documents, items or communications for

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which protection is not warranted are not swept unjustifiably within the ambit of this

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Order.

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Pursuant to the Federal Rules of Civil Procedure and applicable local rules,

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mass, indiscriminate or routinized designations are prohibited. Designations that are

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shown to be clearly unjustified or that have been made for an improper purpose (e.g.,

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to unnecessarily encumber the case development process or to impose unnecessary

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expenses and burdens on other parties) may expose the Designating Party to sanctions.

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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
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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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

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

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or ordered, Disclosure or Discovery Material that qualifies for protection under this

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Order must be clearly so designated before the material is disclosed or produced.

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Designation in conformity with this Order requires:
(a)

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

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

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

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

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contains protected material. If only a portion of the material on a page qualifies for

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protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,

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by making appropriate markings in the margins).

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

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

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

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

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“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

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copied and produced, the Producing Party must determine which documents, or

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portions thereof, qualify for protection under this Order. Then, before producing the

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specified documents, the Producing Party must affix the CONFIDENTIAL legend to

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each page that contains Protected Material. If only a portion of the material on a page

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

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

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(b)

for testimony given in deposition or in other pretrial or trial

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proceedings, that the Party or non-party offering or sponsoring the testimony identify

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on the record, before the close of the deposition, hearing, or other proceeding, all

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protected testimony, and further specify any portions of the testimony that qualify as
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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“CONFIDENTIAL.” When it is impractical to identify separately each portion of

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testimony that is entitled to protection, and when it appears that substantial portions of

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the testimony may qualify for protection, the Party or nonparty that sponsors, offers, or

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gives the testimony may invoke on the record (before the deposition or proceeding is

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concluded) a right to have up to 20 days to identify the specific portions of the

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testimony as to which protection is sought. Only those portions of the testimony that

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are appropriately designated for protection within the 20 days shall be covered by the

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provisions of this Stipulated Protective Order. Transcript pages containing Protected

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Material must be separately bound by the court reporter, who must affix to the top of

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each such page the legend “CONFIDENTIAL” as instructed by the Party or nonparty

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offering or sponsoring the witness or presenting the testimony

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(c)

for information produced in some form other than documentary and

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

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

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

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

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portion(s).

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5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

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failure to designate qualified information or items as “CONFIDENTIAL” does not,

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standing alone, waive the Designating Party’s right to secure protection under this

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Order for such material. If material is appropriately designated as “CONFIDENTIAL”

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after the material was initially produced, the Receiving Party, on timely notification of

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the designation, must make reasonable efforts to assure that the material is treated in

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accordance with the provisions of this Order.

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6.

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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Timing of Challenges. Any Party or Non-Party may challenge a

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

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Order.
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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6.2

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq.

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6.3

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

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Designating Party. Pursuant to the Federal Rules of Civil Procedure and applicable

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local rules, frivolous challenges, and those made for an improper purpose (e.g., to

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harass or impose unnecessary expenses and burdens on other parties) may expose the

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Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn

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the confidentiality designation, all parties shall continue to afford the material in

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question the level of protection to which it is entitled under the Producing Party’s

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designation until the Court rules on the challenge.

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7.

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ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

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

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

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

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

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

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Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

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

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

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authorized under this Order.

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7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

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Receiving Party may disclose any information or item designated “CONFIDENTIAL”

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only to:

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

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

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necessary to disclose the information for this Action;

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(b) the officers, directors, and employees (including House Counsel) of
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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the Receiving Party to whom disclosure is reasonably necessary for this Action;

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

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

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

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(d) the court and its personnel;

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(e) court reporters and their staff;

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

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

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

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(g) during their depositions, witnesses in the action to whom disclosure is

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reasonably necessary and who have signed the “Agreement to Be Bound by Protective

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Order” (Exhibit A). Pages of transcribed deposition testimony or exhibits to

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depositions that reveal Protected Material must be separately bound by the court

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reporter and may not be disclosed to anyone except as permitted under this Stipulated

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Protective Order.

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(h) the author and recipients of the document or the original source of the
information.

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(i) any mediator or settlement officer, and their supporting personnel,

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mutually agreed upon by any of the parties engaged in settlement discussions.

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8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

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OTHER LITIGATION

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If a Party is served with a subpoena or a court order issued in other litigation that

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

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“CONFIDENTIAL” that Party must:

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(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
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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or order is subject to this Protective Order. Such notification shall include a copy of

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this Stipulated Protective Order; and

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(c) cooperate with respect to all reasonable procedures sought to be
pursued by the Designating Party whose Protected Material may be affected.

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

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

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

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or order issued, unless the Party has obtained the Designating Party’s permission. The

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Designating Party shall bear the burden and expense of seeking protection in that court

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of its confidential material and nothing in these provisions should be construed as

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authorizing or encouraging a Receiving Party in this Action to disobey a lawful

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directive from another court.

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9.

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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

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

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

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

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prohibiting a Non-Party from seeking additional protections.

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(b)

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

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

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

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confidential information, then the Party shall:

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

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

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agreement with a Non-Party;

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(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
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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specific description of the information requested; and

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(3) make the information requested available for inspection by the
Non-Party, if requested.

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(c)

If the Non-Party fails to seek a protective order from this court

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

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

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

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

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

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

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of seeking protection in this court of its Protected Material.

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10.

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UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

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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

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the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

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all unauthorized copies of the Protected Material, (c) inform the person or persons to

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whom unauthorized disclosures were made of all the terms of this Order, and (d)

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request such person or persons to execute the “Acknowledgment and Agreement to Be

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Bound” that is attached hereto as Exhibit A.

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11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

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PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

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

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

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

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

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privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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

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

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parties may incorporate their agreement in the stipulated protective order submitted to

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the court.

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12.

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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.

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12.2 Right to Assert Other Objections. By stipulating to the entry of this

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Protective Order, no Party waives any right it otherwise would have to object to

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disclosing or producing any information or item on any ground not addressed in this

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Stipulated Protective Order. Similarly, no Party waives any right to object on any

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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

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Protected Material must comply with Local Civil Rule 79-5. Protected Material may

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only be filed under seal pursuant to a court order authorizing the sealing of the specific

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Protected Material at issue. If a Party’s request to file Protected Material under seal is

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denied by the court, then the Receiving Party may file the information in the public

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record unless otherwise instructed by the court.

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13.

FINAL DISPOSITION

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After the final disposition of this Action, as defined in paragraph 4, within 30

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days of a written request by the Designating Party, each Receiving Party must return

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

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

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

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

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

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or entity, to the Designating Party) by the 30 day deadline that (1) identifies (by

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category, where appropriate) all the Protected Material that was returned or destroyed
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[PROPOSED] STIPULATED PROTECTIVE ORDER
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and (2) affirms that the Receiving Party has not retained any copies, abstracts,

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compilations, summaries or any other format reproducing or capturing any of the

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Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

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

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legal memoranda, correspondence, deposition and trial exhibits, expert reports,

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attorney work product, and consultant and expert work product, even if such materials

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contain Protected Material.

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14.

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VIOLATION
Pursuant to the Federal Rules of Civil Procedure and applicable local rules, any

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violation of this Order may be punished by appropriate measures including, without

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limitation, contempt proceedings and/or monetary sanctions.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: March 20, 2018

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ISOLA LAW GROUP, LLP
By:

/s/ David R. Isola
DAVID R. ISOLA
Attorneys for Plaintiff and Counter-Defendant,
WORLD CLEANERS, INC.

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Dated: March 20, 2018

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SMITH  ELLISON
By:

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Attorneys for Third Party Defendant
HARTFORD FIRE INSURANCE COMPANY

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Dated: March 20, 2018

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/s/ John A. Chatowski
GARY R. SELVIN
JOHN A. CHATOWSKI
Attorneys for Defendant, CounterComplainant, and Third Party Plaintiff
OAKWOOD INSURANCE COMPANY

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SELVIN WRAITH HALMAN LLP
By:

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/s/ Philip E. Smith
PHILIP E. SMITH

//
//
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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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"I hereby attest that I have on file all holographic signatures corresponding to any

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signatures indicated by a conformed signature (/s/) within this e-filed document."

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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DATED: March 21, 2018

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_____________________________________

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HONORABLE ROZELLA A. OLIVER

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United States Magistrate Judge

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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO

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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

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_________________ [print or type full address], declare under penalty of perjury that I

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have read in its entirety and understand the Stipulated Protective Order that was issued

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by the United States District Court for the Central District of California on [date] in the

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case of World Cleaners, Inc. v. Central National Insurance Company of Omaha, now

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known as Oakwood Insurance Company, Case No. 2:17-cv-04731-DSF-RAO. I agree

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to comply with and to be bound by all the terms of this Stipulated Protective Order and

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I understand and acknowledge that failure to so comply could expose me to sanctions

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and punishment in the nature of contempt. I solemnly promise that I will not disclose

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in any manner any information or item that is subject to this Stipulated Protective

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Order to any person or entity except in strict compliance with the provisions of this

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Order. I further agree to submit to the jurisdiction of the United States District Court

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for the Central District of California for enforcing the terms of this Stipulated

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Protective Order, even if such enforcement proceedings occur after termination of this

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action. I hereby appoint __________________________ [print or type full name] of

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_______________________________________ [print or type full address and

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telephone number] as my California agent for service of process in connection with

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this action or any proceedings related to enforcement of this Stipulated Protective

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Order.

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Date: ______________________________________

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City and State where sworn and signed: ______________________________

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Printed name: _______________________________

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Signature: __________________________________

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249901.doc

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[PROPOSED] STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-cv-04731-DSF-RAO