Mario Ruiz et al v. Shamrock Foods Company

Filing 22

ORDER APPROVING STIPULATED PROTECTIVE ORDER by Magistrate Judge Alexander F. MacKinnon. Re Stipulation for Protective Order 21 . (ib)

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1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA 3 4 5 6 MARIO RUIZ, RAUL GUERRERO, and ROBERT TORRES on behalf of themselves and all others similarly situated, 9 10 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER Plaintiffs, 7 8 CASE NO. 2:17-cv-06017-SVW-AFM v. Complaint Filed: August 14, 2017 SHAMROCK FOODS COMPANY, an Arizona Corporation, and DOES 1 to 10, inclusive, Trial Date: None Set Defendants. 11 12 Based upon the parties’ stipulation and good cause showing, the court hereby 13 issues the protective order on the following terms: 14 1. 15 A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, 16 proprietary or private information for which special protection from public 17 disclosure and from use for any purpose other than prosecuting this litigation may 18 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 19 enter the following Stipulated Protective Order. The parties acknowledge that this 20 Order does not confer blanket protections on all disclosures or responses to 21 discovery and that the protection it affords from public disclosure and use extends 22 only to the limited information or items that are entitled to confidential treatment 23 under the applicable legal principles. 24 B. 25 This action is likely to involve trade secrets, and confidential and proprietary GOOD CAUSE STATEMENT 26 information for which special protection from public disclosure and from use for 27 any purpose other than prosecution of this action is warranted. Such confidential 28 and proprietary materials and information consist of, among other things, 1 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 1 confidential business or financial information, information regarding confidential 2 business practices, or other confidential research, development, or commercial 3 information (including information implicating privacy rights of employees and 4 other third parties), information otherwise generally unavailable to the public, or 5 which may be privileged or otherwise protected from disclosure under state or 6 federal statutes, court rules, case decisions, or common law. Accordingly, to 7 expedite the flow of information, to facilitate the prompt resolution of disputes over 8 confidentiality of discovery materials, to adequately protect information the parties 9 are entitled to keep confidential, to ensure that the parties are permitted reasonable 10 necessary uses of such material in preparation for and in the conduct of trial, to 11 address their handling at the end of the litigation, and serve the ends of justice, a 12 protective order for such information is justified in this matter. It is the intent of the 13 parties that information will not be designated as confidential for tactical reasons 14 and that nothing be so designated without a good faith belief that it has been 15 maintained in a confidential, non-public manner, and there is good cause why it 16 should not be part of the public record of this case. 17 18 19 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL The parties further acknowledge, as set forth in Section 12.3, below, that this 20 Stipulated Protective Order does not entitle them to file confidential information 21 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 22 and the standards that will be applied when a party seeks permission from the court 23 to file material under seal. 24 There is a strong presumption that the public has a right of access to judicial 25 proceedings and records in civil cases. In connection with non-dispositive motions, 26 good cause must be shown to support a filing under seal. See Kamakana v. City and 27 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 28 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 2 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 1 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 2 require good cause showing), and a specific showing of good cause or compelling 3 reasons with proper evidentiary support and legal justification, must be made with 4 respect to Protected Material that a party seeks to file under seal. The parties’ mere 5 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 6 without the submission of competent evidence by declaration, establishing that the 7 material sought to be filed under seal qualifies as confidential, privileged, or 8 otherwise protectable—constitute good cause. Further, if a party requests sealing related to a dispositive motion or trial, 9 10 then compelling reasons, not only good cause, for the sealing must be shown, and 11 the relief sought shall be narrowly tailored to serve the specific interest to be 12 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 13 2010). For each item or type of information, document, or thing sought to be filed 14 or introduced under seal in connection with a dispositive motion or trial, the party 15 seeking protection must articulate compelling reasons, supported by specific facts 16 and legal justification, for the requested sealing order. Again, competent evidence 17 supporting the application to file documents under seal must be provided by 18 declaration. Any document that is not confidential, privileged, or otherwise protectable in 19 20 its entirety will not be filed under seal if the confidential portions can be redacted. 21 If documents can be redacted, then a redacted version for public viewing, omitting 22 only the confidential, privileged, or otherwise protectable portions of the document, 23 shall be filed. Any application that seeks to file documents under seal in their 24 entirety should include an explanation of why redaction is not feasible. 25 2. 26 DEFINITIONS 2.1 Action: This pending class action in this Court entitled, Mario Ruiz, 27 Raul Guerrero, and Robert Torres on behalf of themselves and all others similarly 28 situated, v. Shamrock Foods Company, an Arizona Corporation, and DOES 1 to 3 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 1 2 3 4 10, Case No. 2:17-cv-06017-SVW-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 5 how it is generated, stored or maintained) or tangible things that qualify for 6 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 7 the Good Cause Statement. 8 9 10 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 11 items that it produces in disclosures or in responses to discovery as 12 “CONFIDENTIAL.” 13 2.6 Disclosure or Discovery Material: all items or information, regardless 14 of the medium or manner in which it is generated, stored, or maintained (including, 15 among other things, testimony, transcripts, and tangible things), that are produced 16 or generated in disclosures or responses to discovery in this matter. 17 2.7 Expert: a person with specialized knowledge or experience in a matter 18 pertinent to the litigation who has been retained by a Party or its counsel to serve as 19 an expert witness or as a consultant in this Action. 20 2.8 House Counsel: attorneys who are employees of a party to this Action. 21 House Counsel does not include Outside Counsel of Record or any other outside 22 counsel. 23 24 25 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 26 party to this Action but are retained to represent or advise a party to this Action and 27 have appeared in this Action on behalf of that party or are affiliated with a law firm 28 that has appeared on behalf of that party, and includes support staff. 4 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 2.11 Party: any party to this Action, including all of its officers, directors, 1 2 employees, consultants, retained experts, and Outside Counsel of Record (and their 3 support staffs). 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 4 5 Discovery Material in this Action. 6 2.13 Professional Vendors: persons or entities that provide litigation 7 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 8 demonstrations, and organizing, storing, or retrieving data in any form or medium) 9 and their employees and subcontractors. 2.14 Protected Material: any Disclosure or Discovery Material that is 10 11 designated as “CONFIDENTIAL.” 2.15 Receiving Party: a Party that receives Disclosure or Discovery 12 13 Material from a Producing Party. 14 3. SCOPE 15 The protections conferred by this Stipulation and Order cover not only 16 Protected Material (as defined above), but also (1) any information copied or 17 extracted from Protected Material; (2) all copies, excerpts, summaries, or 18 compilations of Protected Material; and (3) any testimony, conversations, or 19 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 20 21 trial judge. This Order does not govern the use of Protected Material at trial. 22 4. 23 DURATION Even after final disposition of this litigation, the confidentiality obligations 24 imposed by this Order shall remain in effect until a Designating Party agrees 25 otherwise in writing or a court order otherwise directs. Final disposition shall be 26 deemed to be the later of (1) dismissal of all claims and defenses in this action, with 27 or without prejudice; and/or (2) final judgment herein after the completion and 28 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 5 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 1 including the time limits for filing any motions or applications for extension of time 2 pursuant to applicable law. Once a case proceeds to trial, information that was designated as 3 4 CONFIDENTIAL or maintained pursuant to this protective order used or 5 introduced as an exhibit at trial becomes public and will be presumptively available 6 to all members of the public, including the press, unless compelling reasons 7 supported by specific factual findings to proceed otherwise are made to the trial 8 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing 9 “good cause” showing for sealing documents produced in discovery from 10 “compelling reasons” standard when merits-related documents are part of court 11 record). Accordingly, the terms of this protective order do not extend to information 12 used or introduced as an exhibit at trial. 13 5. 14 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 15 Each Party or Non-Party that designates information or items for protection under 16 this Order must take care to limit any such designation to specific material that 17 qualifies under the appropriate standards. The Designating Party must designate for 18 protection only those parts of material, documents, items or oral or written 19 communications that qualify so that other portions of the material, documents, 20 items or communications for which protection is not warranted are not swept 21 unjustifiably within the ambit of this Order. 22 Mass, indiscriminate or routinized designations are prohibited. Designations 23 that are shown to be clearly unjustified or that have been made for an improper 24 purpose (e.g., to unnecessarily encumber the case development process or to 25 impose unnecessary expenses and burdens on other parties) may expose the 26 Designating Party to sanctions. 27 If it comes to a Designating Party’s attention that information or items that it 28 designated for protection do not qualify for protection, that Designating Party must 6 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 1 2 promptly notify all other Parties that it is withdrawing the inapplicable designation. 5.2 Manner and Timing of Designations. Except as otherwise provided in 3 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 4 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 5 under this Order must be clearly so designated before the material is disclosed or 6 produced. 7 8 9 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 10 proceedings), that the Producing Party affix at a minimum, the legend 11 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 12 contains protected material. If only a portion of the material on a page qualifies for 13 protection, the Producing Party also must clearly identify the protected portion(s) 14 (e.g., by making appropriate markings in the margins). 15 A Party or Non-Party that makes original documents available for inspection 16 need not designate them for protection until after the inspecting Party has indicated 17 which documents it would like copied and produced. During the inspection and 18 before the designation, all of the material made available for inspection shall be 19 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 20 documents it wants copied and produced, the Producing Party must determine 21 which documents, or portions thereof, qualify for protection under this Order. Then, 22 before producing the specified documents, the Producing Party must affix the 23 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 24 portion of the material on a page qualifies for protection, the Producing Party also 25 must clearly identify the protected portion(s) (e.g., by making appropriate markings 26 in the margins). 27 28 (b) for testimony given in depositions that the Designating Party identifies the Disclosure or Discovery Material on the record, within 30 days of 7 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 1 receipt of the deposition transcript all protected testimony. (c) for information produced in some form other than documentary and 2 3 for any other tangible items, that the Producing Party affix in a prominent place on 4 the exterior of the container or containers in which the information is stored the 5 legend “CONFIDENTIAL.” If only a portion or portions of the information 6 warrants protection, the Producing Party, to the extent practicable, shall identify the 7 protected portion(s). 5.3 8 Inadvertent Failures to Designate. If timely corrected upon discovery, 9 an inadvertent failure to designate qualified information or items does not, standing 10 alone, waive the Designating Party’s right to secure protection under this Order for 11 such material. Upon timely correction of a designation, the Receiving Party must 12 make reasonable efforts to assure that the material is treated in accordance with the 13 provisions of this Order. 14 6. 15 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 16 designation of confidentiality at any time that is consistent with the Court’s 17 Scheduling Order. 18 19 20 21 22 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37-1 et seq. 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint stipulation pursuant to Local Rule 37-2. 6.4 The burden of persuasion in any such challenge proceeding shall be on 23 the Designating Party. Frivolous challenges, and those made for an improper 24 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 25 parties) may expose the Challenging Party to sanctions. Unless the Designating 26 Party has waived or withdrawn the confidentiality designation, all parties shall 27 continue to afford the material in question the level of protection to which it is 28 entitled under the Producing Party’s designation until the Court rules on the 8 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 1 challenge. 2 7. 3 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 4 disclosed or produced by another Party or by a Non-Party in connection with this 5 Action only for prosecuting, defending or attempting to settle this Action. Such 6 Protected Material may be disclosed only to the categories of persons and under the 7 conditions described in this Order. When the Action has been terminated, a 8 Receiving Party must comply with the provisions of section 13 below (FINAL 9 DISPOSITION). 10 Protected Material must be stored and maintained by a Receiving Party at a 11 location and in a secure manner that ensures that access is limited to the persons 12 authorized under this Order. 13 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 14 otherwise ordered by the court or permitted in writing by the Designating Party, a 15 Receiving Party may disclose any information or item designated 16 “CONFIDENTIAL” only to: 17 18 19 (a) where the Receiving Party is a named plaintiff, to other named plaintiffs (Mario Ruiz, Raul Guerrero and/or Robert Torres) in this action; (b) the Receiving Party’s Outside Counsel of Record in this Action, as 20 well as employees of said Outside Counsel of Record to whom it is reasonably 21 necessary to disclose the information for this Action; 22 23 24 (c) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; (d) Experts (as defined in this Order) of the Receiving Party to whom 25 disclosure is reasonably necessary for this Action and who have signed the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (e) the court and its personnel; 28 (f) court reporters and their staff; 9 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 (g) professional jury or trial consultants, mock jurors, and Professional 1 2 Vendors to whom disclosure is reasonably necessary for this Action and who have 3 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (h) an individual who authored or has personal knowledge of that 4 5 information provided that individual (1) has signed the form attached as Exhibit A 6 hereto, and (2) is not permitted to keep any confidential information, unless 7 otherwise agreed by the Designating Party or ordered by the court; 8 (i) during their depositions, witnesses, and attorneys for witnesses, in 9 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 10 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 11 they will not be permitted to keep any confidential information, unless otherwise 12 agreed by the Designating Party or ordered by the court. Pages of transcribed 13 deposition testimony or exhibits to depositions that reveal Protected Material may 14 be separately bound by the court reporter and may not be disclosed to anyone 15 except as permitted under this Stipulated Protective Order; and (j) any mediator or settlement officer, and their supporting personnel, 16 17 mutually agreed upon by any of the parties engaged in settlement discussions. 7.3. 18 Putative Class Member Information. Contact information and any 19 other identifying information for putative class members provided in this action 20 shall only be used for purposes of pre-class certification discovery in this action, 21 and for no other reason. If the class is certified, however, the information may be 22 used during the pendency of this action, but solely for the purpose of this litigation. 23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 24 IN OTHER LITIGATION 25 If a Party is served with a subpoena or a court order issued in other litigation 26 that compels disclosure of any information or items designated in this Action as 27 “CONFIDENTIAL,” that Party must: 28 (a) promptly notify in writing the Designating Party. Such notification 10 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 1 shall include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or 2 3 order to issue in the other litigation that some or all of the material covered by the 4 subpoena or order is subject to this Protective Order. Such notification shall include 5 a copy of this Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be 6 7 pursued by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party 8 9 served with the subpoena or court order shall not produce any information 10 designated in this action as “CONFIDENTIAL” before a determination by the court 11 from which the subpoena or order issued, unless the Party has obtained the 12 Designating Party’s permission. The Designating Party shall bear the burden and 13 expense of seeking protection in that court of its confidential material and nothing 14 in these provisions should be construed as authorizing or encouraging a Receiving 15 Party in this Action to disobey a lawful directive from another court. 16 9. 17 18 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 19 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 20 produced by Non-Parties in connection with this litigation is protected by the 21 remedies and relief provided by this Order. Nothing in these provisions should be 22 construed as prohibiting a Non-Party from seeking additional protections. 23 (b) In the event that a Party is required, by a valid discovery request, to 24 produce a Non-Party’s confidential information in its possession, and the Party is 25 subject to an agreement with the Non-Party not to produce the Non-Party’s 26 confidential information, then the Party shall: 27 28 (1) promptly notify in writing the Requesting Party and the NonParty that some or all of the information requested is subject to a confidentiality 11 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 1 agreement with a Non-Party; (2) promptly provide the Non-Party with a copy of the 2 3 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 4 reasonably specific description of the information requested; and (3) make the information requested available for inspection by 5 6 the Non-Party, if requested. (c) If the Non-Party fails to seek a protective order from this court 7 8 within 14 days of receiving the notice and accompanying information, the 9 Receiving Party may produce the Non-Party’s confidential information responsive 10 to the discovery request. If the Non-Party timely seeks a protective order, the 11 Receiving Party shall not produce any information in its possession or control that 12 is subject to the confidentiality agreement with the Non-Party before a 13 determination by the court. Absent a court order to the contrary, the Non-Party 14 shall bear the burden and expense of seeking protection in this court of its Protected 15 Material. 16 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 17 18 Protected Material to any person or in any circumstance not authorized under this 19 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 20 writing the Designating Party of the unauthorized disclosures, (b) use its best 21 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 22 person or persons to whom unauthorized disclosures were made of all the terms of 23 this Order, and (d) request such person or persons to execute the “Acknowledgment 24 and Agreement to Be Bound” that is attached hereto as Exhibit A. 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 12 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 1 protection, the obligations of the Receiving Parties are those set forth in Federal 2 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 3 whatever procedure may be established in an e-discovery order that provides for 4 production without prior privilege review. Pursuant to Federal Rule of Evidence 5 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 6 of a communication or information covered by the attorney-client privilege or work 7 product protection, the parties may incorporate their agreement in the stipulated 8 protective order submitted to the court. 9 12. 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 10 11 MISCELLANEOUS person to seek its modification by the Court in the future. 12 12.2 Right to Assert Other Objections. By stipulating to the entry of this 13 Protective Order, no Party waives any right it otherwise would have to object to 14 disclosing or producing any information or item on any ground not addressed in 15 this Stipulated Protective Order. Similarly, no Party waives any right to object on 16 any ground to use in evidence of any of the material covered by this Protective 17 Order. 18 12.3 Filing Protected Material. A Party that seeks to file under seal any 19 Protected Material must comply with Local Civil Rule 79-5. Protected Material 20 may only be filed under seal pursuant to a court order authorizing the sealing of the 21 specific Protected Material at issue. If a Party’s request to file Protected Material 22 under seal is denied by the court, then the Receiving Party may file the information 23 in the public record unless otherwise instructed by the court. 24 13. 25 FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 4, within 60 26 days of a written request by the Designating Party, each Receiving Party must 27 return all Protected Material to the Producing Party or destroy such material. As 28 used in this subdivision, “all Protected Material” includes all copies, abstracts, 13 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017 1 compilations, summaries, and any other format reproducing or capturing any of the 2 Protected Material. Whether the Protected Material is returned or destroyed, the 3 Receiving Party must submit a written certification to the Producing Party (and, if 4 not the same person or entity, to the Designating Party) by the 60 day deadline that 5 (1) identifies (by category, where appropriate) all the Protected Material that was 6 returned or destroyed and (2) affirms that the Receiving Party has not retained any 7 copies, abstracts, compilations, summaries or any other format reproducing or 8 capturing any of the Protected Material. Notwithstanding this provision, Counsel 9 are entitled to retain an archival copy of all pleadings, motion papers, trial, 10 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 11 and trial exhibits, expert reports, attorney work product, and consultant and expert 12 work product, even if such materials contain Protected Material. Any such archival 13 copies that contain or constitute Protected Material remain subject to this Protective 14 Order as set forth in Section 4 (DURATION). 15 14. 16 17 18 VIOLATION Any violation of this Order may be punished by appropriate measures including, without limitation, contempt proceedings and/or monetary sanctions. DATED: 11/15/2017 19 20 Alexander F. MacKinnon United States Magistrate Judge 21 22 23 24 25 26 27 28 14 [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017

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