UL LLC v. Gangsong Group Corp. et al

Filing 44

PROTECTIVE ORDER by Magistrate Judge Charles F. Eick re Stipulation for Protective Order 43 . (sp)

se 2:17-cv-08166-DSF-E Document 43-1 Filed 11/29/17 Page 1 of 20 Page ID #:375

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GREENBERG TRAURIG,LLP
MATTHEW R. GERS~IlVIAN(SBN 253031)
[e-mail]
BENJAMIN S. KURTZ(SBN 280515)
[e-mail]
1840 Century Park East, Suite 1900
Los Angeles, CA 90067-2121
Telephone: [phone] /Facsimile: 310-586-7800
Attorneys for PlaintiffUL LLC

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8 AXIS LEGAL COUNSEL
RABEH M. A. SOOFI(SBN 276015)
9 rsoofi@~islegalca.com
10 5670 Wilshire Blvd., 18th Floor
Los Angeles, CA 90036
1 1 Telephone: [phone] /Facsimile: 213-403-0132
12 Attorneys for Defendants Gangsong Group Corp. a/k/a Logistics Public Warehouse,
Flying Medical USALLC,and Thomas Soon Chiah
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UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA

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Case No.: 2:17-cv-08166-DSF-Ex

UL LLC,
Plaintiff,

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v.

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]STIPULATED
PROTECTIVE ORDER

Gangsong Group Corp., a California
corporation; Flying Medical USA LLC,a
California company; Logistic Public
Warehouse, a California company; Thomas
Soon Chiah, an individual; Shenzhen Kebe
Technology Co. Ltd., a foreign company;
Jing Hua Zhou, an individual; Shenzhen
Leidisi Electronics Technology Co., Ltd., a
f
oreign company; TRC International Corp.,
a California corporation; Sum Fortune
International Group, a California
corporation; Defang USA,LLC,a
California company; Sun Defang, an

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(
DISCOVERY MATTER)

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individual; ManSeeManWant LLC, an
Illinois company; James Ellenberg, an
2 individual; and John Does 1-10,
3 individuals,
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Defendants.

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1.

PRELIMINARY STATEMENT
A. Purposes and Limitations
Discovery in this action is likely to involve production of confidential,

proprietary, or private information for which special protection from public disclosure
and from use for any purpose other than prosecuting this litigation may be warranted.
Accordingly, the parties hereby stipulate to and petition the Court to enter the following
Stipulated Protective Order. The parties acknowledge that this Order does not confer
blanket protections on all disclosures or responses to discovery and that the protection it
affords from public disclosure and use extends only to the limited information or items
that are entitled to confidential treatment under the applicable legal principles. The
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parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated
Protective Order does not entitle them to file confidential information under seal; Civil
Local Rule 79-5 sets forth the procedures that must be followed and the standards that
will be applied when a party seeks permission from the court to file material under seal.
The entry of this Stipulation and Protective Order does not alter, waive, modify, or
abridge any right, privilege or protection otherwise available to the Party with respect to
the discovery of matters, including but not limited to the right to assert privileges or
another party's right to contest such assertions.
B.

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Good Cause Statement

This action is likely to involve proprietary, confidential, or private information for
which special protection from public disclosure and from use for any other purpose
other than prosecuting this litigation may be warranted. Such confidential and
proprietary materials and information consist of, among other things, confidential
business or financial information, trade secrets, information regarding confidential
business practices, or other confidential research, development, or commercial
information, information otherwise generally unavailable to the public, or which may
be privileged or otherwise protected from disclosure under state or federal statutes,
court rules, case decisions, or common law. Accordingly, to expedite the flow of
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information, to facilitate the prompt resolution of disputes over confidentiality of
discovery materials, to adequately protect information the parties are entitled to keep
confidential, to ensure that the parties are permitted reasonable necessary uses of such
material in preparation for and in the conduct oftrial, to address their handling at the
end ofthe litigation, and serve the ends ofjustice, a protective order for such
information is justified in this matter. It is the intent ofthe parties that information will
not be designated as confidential for tactical reasons and that nothing be so designated
without a good faith beliefthat it has been maintained in a confidential, non-public
manner, and there is good cause why it should not be part ofthe public record of this

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case.
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DEFINITIONS
2.1

Action: This actionUL LLC v. Gangsong Group Corp. et al, Central

District of California Case 2:17-cv-08166-DSF-E —and any actions that are
consolidated with this action after entry of this order.
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.2

Challen~~rty: a Party or Non-Party that challenges the designation of

information or items under this Order.
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.3

"CONFIDENTIAL"Information or Items: information (regardless of how it

is generated, stored or maintained) or tangible things that qualify for protection under
Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
Statement.
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.4

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

fl.
support staf
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Desi~natin~Part_v: a Party or Non-Party that designates information or items

that it produces in disclosures or in responses to discovery as "CONFIDENTIAL" or
UNRELATED."
"
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.6

Disclosure or Discovery Material: all items or information, regardless ofthe

medium or manner in which it is generated, stored, or maintained (including, among
other things, testimony, transcripts, and tangible things), that are produced or generated
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in disclosures or responses to discovery in this matter.
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Expert: a person with specialized knowledge or experience in a matter

pertinent to the litigation.
2.8

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

House Counsel does not include Outside Counsel of Record or any other outside
counsel.
2.9

Non-Pa :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
this Action but are retained to represent or advise a party to this Action and have
appeared in this Action on behalf ofthat party or are affiliated with a law firm which
has appeared on behalf ofthat party, and includes support staff.
2.11 etP

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

employees, consultants, retained experts, and Outside Counsel ofRecord (and their
support staffs).
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.12 Producingarty: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
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.13 Professional Vendors: persons or entities that provide litigation support
services (e.g., photocopying, videotaping, translating, preparing e~ibits or
demonstrations, and organizing, storing, or retrieving data in any form or medium)and
their employees and subcontractors.
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.14 Protected Material: any Disclosure or Discovery Material that is designated
as "CONFIDENTIAL" or "UNRELATED."
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.15 Receiving Party: a Party that receives Disclosure or Discovery Material
rom a Producing Party.
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.16 "UNRELATED MATERIAL": all items or information, information, files,

records, emails, texts, banking records, financial transactions, or other data legitimately
unrelated and/or not relevant to any party's claims or defenses or this action, regardless
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ofthe medium or manner in which it is generated, stored, or maintained (including,
among other things, testimony, transcripts, and tangible things).
3.

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

Material (as defined above), but also (1) any information copied or extracted from
Protected Material;(2) all copies, excerpts, summaries, or compilations ofProtected
Material;(3)any testimony, conversations, or presentations by Parties or their Counsel
that might reveal Protected Material; (4)portions of deposition or other transcripts and
exhibits thereto that contain, summarize, or reflect the content ofany such Protected
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Material;(5)portions of briefs, memoranda, or any other writings filed with the Court
and e~ibits thereto that contain, summarize, or reflect the content of any such Protected
Material; and (6) written discovery responses and answers that contain, summarize, or
reflect the content of any such Protected Material. This material shall be used only for
the purposes of this Action and any related appellate proceeding, and not for any other
business, competitive, personal, private, public, or other purpose whatsoever. However,
the protections conferred by this Stipulation and Order do not cover the following
information:(a)any information that is in the public domain at the time of disclosure to
a Receiving Party or that becomes part ofthe public domain after its disclosure to a
Receiving Party as a result of publication not involving a violation ofthis Order,
including becoming part of the public record through trial or otherwise; and (b)any
information known to the Receiving Party prior to the disclosure or obtained by the
Receiving Party after the disclosure from a source who obtained the information
lawfully and under no obligation of confidentiality to the Designating Party.

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Any use of Protected Material at trial shall be governed by the orders ofthe trial
judge or by separate agreement. This Order does not govern the use ofProtected
Material at trial..
4.

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

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imposed by this Order shall remain in effect until a Designating Party agrees otherwise
in writing or a court order otherwise directs. Final disposition shall be deemed to be the
later of(1) dismissal of all claims and defenses in this action, with or without prejudice;
and (2)final judgment herein after the completion and exhaustion of all appeals,
rehearings, remands, trials, or reviews of this action, including the time limits for filing
any motions or applications for extension of time pursuant to applicable law.
5.

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Desi~natin~ Material for Protection. Each

Party or Non-Party that designates information or items for protection under this Order
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must take care to limit any such designation to specific material that qualifies under the
appropriate standards. To the extent practicable, the Designating Party must designate
f protection only those parts of material, documents, items, or oral or written
or
communications that qualify so that other portions ofthe material, documents, items, or
communications for which protection is not warranted are not swept unjustifiably
within the ambit of this Order.
Mass, indiscriminate, or routinized designations are prohibited. Designations

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that are shown to be clearly unjustified or that have been made for an improper purpose
(
e.g., to unnecessarily encumber the case development process or to impose
unnecessary expenses and burdens on other parties) may expose the Designating Party
to sanctions.
If it comes to a Designating Pariy's attention that information or items that it
designated for protection do not qualify for protection, that Designating Party must
promptly notify all other Parties that it is withdrawing the inapplicable designation.
5.2

Manner and Timing of Designations. Except as otherwise provided in this

Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
ordered, Disclosure or Discovery Material that qualifies for protection as
"
CONFIDENTIAL"Information or Items under this Order must be clearly so
designated before the material is disclosed or produced. Designations ofProtected
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Material made prior to the entry ofthe Court's approval of this Order shall be effective
prospectively and made pursuant to such Order.
Designation as "CONFIDENTIAL" in conformity with this Order requires:
(
a)

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

but excluding transcripts of depositions or other pretrial or trial proceedings), that the
Producing Party affix at a minimum,the legend "CONFIDENTIAL" to each page or
portions of pages that contains confidential Protected Material.
A Party or Non-Party that makes original documents available for inspection need
not designate them for protection until after the inspecting Party has indicated which
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documents it would like copied and produced. During the inspection and before the
designation, all ofthe material made available for inspection shall be deemed
"
CONFIDENTIAL." After the inspecting Party has identified the documents it wants
copied and produced, the Producing Party must determine which documents, or
portions thereof, qualify for protection under this Order. Then, before producing the
specified documents, the Producing Party must affix the "CONFIDENTIAL" legend to
each page that contains confidential Protected Material.
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b)

for testimony given in deposition, that the Designating Party identify all

protected testimony on the record, before the close ofthe deposition. If a designation is
made, the CONFIDENTIAL portions and exhibits, if filed with the Court, shall be
subject to the filing requirements set forth in Paragraph 12.3 below. If any depositions
are videotaped or digitally recorded, those portions ofthe videotape or recording
corresponding to portions ofthe deposition transcript designated as CONFIDENTIAL
shall be afforded the same status.
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c)

for testimony given in other pretrial proceedings, that the Designating Party

identify on the record, before the close of the hearing or other proceeding, all protected
testimony.
(
d)

for information produced in some form other than documentary and for any

other tangible items, that the Producing Party affix in a prominent place on the exterior
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ofthe container or containers in which the information is stored the legend
"
CONFIDENTIAL."If only a portion or portions ofthe information warrants
protection, the Producing Party, to the extent practicable, shall identify the protected
portion(s).
5.3

Inadvertent Failures to Desi~.If timely corrected, an inadvertent failure

to designate qualified information or items does not, standing alone, waive the
Designating Party's right to secure protection under this Order for such material. Upon
timely correction of a designation, the Receiving Party must make reasonable efforts to
assure that the material is treated in accordance with the provisions of this Order. The
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Designating Party shall provide substitute copies ofthe qualified information or items
bearing the corrected designation. The Receiving Party shall return or certify the
destruction ofthe undesignated Protected Material.
5.4

Manner of"UNRELATED" Designations and Access to "UNRELATED

MATERIAL." During the course ofthe discovery in this matter, the parties may
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intentionally or inadvertently collect, gain access to, view, or otherwise receive
UNRELATED MATERIAL." The following procedures shall govern the handling of
"
UNRELATED MATERIAL":
"

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(
a) "UNRELATED MATERIAL" may be comprised of all, some, or partial
19 data, electronic/digital records, hard-copy paper records, native files, or portions thereof.

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In designating "UNRELATED MATERIAL,"the Designating Party shall

21I provide sufficient descriptiveness as to the nature of the reasons or grounds on which the
221 content is "iJNRELATED MATERIAL," so as to permit the Receiving Party and Court
23 to evaluate the propriety of such designation. In doing so, the Designating Party shall
2 provide a log for all "UNRELATED MATERIAL" designations, with reference to the
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(
c)

Once material is designated "UNRELATED MATERIAL," whether

27~ originating from a disclosing party or a vendor/third party in possession thereof, said

UNRELATED MATERIAL" may nonetheless, in unredacted form, be produced to the
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" Receiving Party's Outside Counsel of Record in this Action, as well as employees of said
2 Outside Counsel of Record to whom it is reasonably necessary to disclose the
3 information for this Action, subject to and without waiving such designation or the
4 protections afforded by such UNRELATED MATERIAL designation herein. No such
5 disclosures shall abrogate or cause the waiver ofthe protections afforded to
6 "UNRELATED MATERIAL" provided by this Order. Other than as specified herein, no
7 content designated as "UNRELATED MATERIAL" may be cited, reproduced, made
8 public, attached to a court filing, as an e~chibit or otherwise, used in any type of
9 evidentiary or other proceeding (including a deposition) or used for any purpose, nor may
10 it be disclosed to, viewed by, reproduced to, shared with, or accessed by any person other
1 1 the Receiving Party's Outside Counsel ofRecord in this Action, as well as employees of
12 said Outside Counsel of Record to whom it is reasonably necessary to disclose the
13 information for this Action, without the Designating Party's agreement, withdrawal of
14 the designation, or a Court determination that the "UNRELATED MATERIAL"
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designation as to such content is inappropriate.
~d)

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Designations as "iJNRELATED" and/or "CONFIDENTIAL" shall not be

mutually exclusive, and may be made in the alternative.
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(e)

In challenging "UNRELATED MATERIAL" designations, the parties shall

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follow the procedures in Section 6 below.
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6.

CHALLENGING CONFIDENTIALITY/UNRELATED MATERIAL

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DESIGNATIONS
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6.1

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

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of confidentiality or"UNRELATED MATERIAL" at any time that is consistent with
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the Court's Scheduling Order.
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6.2

Meet and Confer. The Challenging Party shall initiate the dispute resolution

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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. Unless the Designating Party has waived or withdrawn the
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designation, all parties shall continue to afford the material in question the level of
protection to which it is entitled under the Producing Party's designation until the Court
rules on the challenge.
6.4 A party's consent and/or stipulation to material being designated as Confidential
or Unrelated Material not prejudice that Party's right to object to such designation and/or
shall not constitute an admission that such Material was properly designated.
7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

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

9 disclosed or produced by another Party or by a Non-Party in connection with this
10 Action only for prosecuting, defending, or attempting to settle this Action. Such
1 1 Protected Material may be disclosed only to the categories of persons and under the
12 conditions described in this Order. When the Action has been terminated, a Receiving
13 Party must comply with the provisions of section 13 below(FINAL DISPOSITION).
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Confidential Material must be stored and maintained by a Receiving Party at a
15I location and in a secure manner that ensures that access is limited to the persons
161 authorized under this Order.
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Disclosure of"CONFIDENTIAL"Information or Items. Unless otherwise

18 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
19 may disclose any information or item designated "CONFIDENTIAL" only to:'
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(
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the Receiving Party's Outside Counsel of Record in this Action, as well as

21I employees of said Outside Counsel of Record to whom it is reasonably necessary to
221 disclose the information for this Action;
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(
b)

the officers, directors, and employees (including House Counsel)ofthe

24 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: (i) to whom
26 disclosure is reasonably necessary for this Action; and (ii) who have signed the
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Acknowledgment and Agreement to Be Bound"(E~ibit 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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professional jury or trial consultants, mock jurors, and Professional

Vendors to whom disclosure is reasonably necessary for this Action and who have
signed the "Acknowledgment and Agreement to Be Bound"(E~ibit A);
(
g)

the author or recipient of a document containing the information or a

custodian or other person who otherwise possessed or knew the information;
(
h)

during their depositions, witnesses, and attorneys for witnesses, in the

Action to whom disclosure is reasonably necessary, provided:(1)the deposing party
requests that the witness sign the "Acknowledgment and Agreement to be Bound" form
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attached as Exhibit A hereto; and(2)they will not be permitted to keep any confidential
information unless they sign Exhibit A, unless otherwise agreed by the Designating
Party or ordered by the court. Pages oftranscribed deposition testimony or exhibits to
depositions that reveal Protected Material may be separately bound by the court reporter
and may not be disclosed to anyone except as permitted under this Stipulated Protective
Order; and

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(
i)

agreed upon by any ofthe parties engaged in settlement discussions.

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any mediator or settlement officer, and their supporting personnel, mutually

(
j)

any named party in the Action who has signed the "Acknowledgment and

Agreement to be Bound"(E~ibit A)
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PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
OTHER LITIGATION
If a Party is served with a subpoena or a court order issued in other litigation that

compels disclosure of any information or items designated in this Action as
CONFIDENTIAL," that Party must:
"
(
a)

promptly notify in writing the Designating Party. Such notification shall

include a copy ofthe 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 ofthe material covered by the subpoena.or
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order is subject to this Protective Order. Such notification shall include a copy of this
Stipulated Protective Order; and
(
c)

cooperate with respect to all reasonable procedures sought to be pursued by

the Designating Party whose Protected Material may be affected.
Ifthe Designating Party timely seeks a protective order, the Party served with the
subpoena or court order shall not produce any information designated in this action as
CONFIDENTIAL" before a determination by the court from which the subpoena or
"
order issued, unless the Party has obtained the Designating Pariy's permission. The
Designating Party shall bear the burden and expense of seeking protection in that court
1D

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of its confidential material and nothing in these provisions should be construed as
authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
f
rom another court.
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ANON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(
a)

Party in this Action and designated as "CONFIDENTIAL." Such information produced
by Non-Parties in connection with this litigation is protected by the remedies and relief
provided by this Order. Nothing in these provisions should be construed as prohibiting a
Non-Party from seeking additional protections.
(
b)

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

~ produce a Non-Party's confidential information in its possession, and the Party is subject
to an agreement with the Non-Party not to produce the Non-Party's confidential
information, then the Party shall:

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The terms of this Order are applicable to information produced by a Non-

(
1)

promptly notify in writing the Requesting Party and the Non-Party

that some or all ofthe information requested is subject to a confidentiality agreement
with allon-Party;

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(
2)

promptly provide the Non-Party with a copy ofthe Stipulated

Protective Order in this Action,the relevant discovery request(s), and a reasonably
specific description ofthe information requested; and
(
3)

make the information requested available for inspection by the Non-

~ Party, if requested.
(
c)

If the Non-Party fails to seek a protective order from this court within 14

days of receiving the notice and accompanying information, the Receiving Pariy may
produce the Non-Party's confidential information responsive to the discovery request. If
the Non-Party timely seeks a protective order, the Receiving Party shall not produce any
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information in its possession or control that is subject to the confidentiality agreement
with the Non-Party before a determination by the court. Absent a court order to the
contrary, the Non-Party shall bear the burden and expense of seeking protection in this
court of its Protected Material.
10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
Protected Material to any person or in any circumstance not authorized under this
Stipulated Protective Order, the Receiving Party must immediately(a) notify in writing
the Designating Party ofthe unauthorized disclosures,(b) use its best efforts to retrieve
all unauthorized copies ofthe Protected Material,(c) inform the person or persons to
whom unauthorized disclosures were made of all the terms of this Order, and (d)request
such person or persons to execute the "Acknowledgment and Agreement to Be Bound"
that is attached hereto as E~ibit A.
1 1.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL
When a Producing Party gives notice to Receiving Parties that certain

inadvertently produced material is subject to a claim of privilege or other protection, the
obligations ofthe Receiving Parties are those set forth in Federal Rule of Civil Procedure
26(b)(5)(B). This provision is not intended to modify whatever procedure may be
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established in an e-discovery order adopted by the parties/the Court under Federal Rule
ofEvidence 502(d).
12. MISCELLANEOUS
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
person to seek its modification by the Court in the future.
12.2 Right to Assert Other Objections. By stipulating to the entry ofthis
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
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ground to use in evidence of any ofthe material covered by this Protective Order.
12.3 Filing Protected Material. A Party that seeks to file under seal any Protected

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Material designated as "CONFIDENTIAL" must comply with Civil Local Rule 79-5.
Such Protected Material may only be filed under seal pursuant to a court order
authorizing the sealing ofthe specific Protected Material at issue. If a Party's request to
f such Protected Material under seal is denied by the court, then the Receiving Party
ile
may file the information in the public record unless otherwise instructed by the court.
13. FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4, within 60 days
of a written request by the Designating Party, each Receiving Party must return all
Protected Material to the Producing Party or destroy such material. As used in this
subdivision,"all Protected Material" includes all copies, abstracts, compilations,
summaries, and any other format reproducing or capturing any ofthe Protected Material.
Whether the Protected Material is returned or destroyed, the Receiving Party must submit
a written confirmation to the Producing Party that affirms that the Receiving Party has
not retained any copies, abstracts, compilations, summaries or any other format
reproducing or capturing any of the Protected Material. Notwithstanding this provision,
Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial,
deposition, and hearing transcripts, legal memoranda, correspondence, deposition and
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trial exhibits, expert reports, attorney work product, and consultant and expert work
product, even if such materials contain Protected Material. Any such archival copies that
contain or constitute Protected Material remain subject to this Protective Order as set
forth in Section 4(DURATION).
14.

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

including, without limitation, contempt proceedings and/or monetary sanctions.

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IT IS SO STIPULATED.

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DATED: November 29,2017

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Respectfully submitted,
GREENBERG TRAURIG,LLP

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By: /s/ Matthew R Gershman
Attorneys for PlaintiffUL LLC

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DATED: November 29, 2017

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Respectfully submitted,
AXIS LEGAL COUNSEL

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By: /s/ Rabeh M. A. Soofi
Attorneys for Defendants Gangsong Group Corp.
a/k/a Logistics Public Warehouse, Flying Medical
USALLC,and Thomas Soon Chiah

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Pursuant to Local Civil Rule 5-4.3.4(a)(2)(i), I hereby attest that Rabeh M. A.
Soofi, on whose behalfthis filing is jointly submitted, has concurred in this filing's
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By: /s/ Matthew R Gershman
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I I IT IS SO ORDERED.

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Dated:

/1/p✓: 2 Z.fJ/7
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Hon. Charles F. Eick
United States Magistrate Judge

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EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
I,

of

declare

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 LTL LLC v. Gangsong Group Corp. et al, Central
District of California Case 2:17-cv-08166-DSF-E, 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
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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 ofthis Order.

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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.

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I hereby appoint

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as my California agent for service of process in connection with
this action or any proceedings related to enforcement of this Stipulated Protective Order.

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Date:
City and State where sworn and signed:
Printed name:
~ Signature:

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