Gold Value International Textile, Inc. v. Zara USA, Inc. et al

Filing 26

PROTECTIVE ORDER by Magistrate Judge Paul L. Abrams: re Stipulation for Protective Order 25 . (See document for details.) (sbou)

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1 2 3 4 5 6 7 8 9 Stephen M. Doniger (SBN 179314) stephen@donigerlawfirm.com Scott Alan Burroughs (SBN 235718) scott@donigerlawfirm.com Trevor W. Barrett (SBN 287174) tbarrett@donigerlawfirm.com Justin M. Gomes (SBN 301793) jgomes@donigerlawfirm.com DONIGER / BURROUGHS 603 Rose Avenue Venice, California 90291 Telephone: (310) 590-1820 Attorneys for Plaintiff 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12 13 14 Case No.: 2:17-cv-08226-DSF-PLAx Honorable Dale S. Fischer Presiding Referred to Hon. Paul L. Abrams GOLD VALUE INTERNATIONAL TEXTILE, INC., 15 16 17 18 Plaintiff, DISCOVERY MATTER v. PROTECTIVE ORDER ZARA USA, INC.; et al., 19 20 Defendants. 21 22 23 24 25 26 27 28 -1PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION On stipulation of the Parties, the Court enters a Protective Order in this 1 2 matter as follows: 3 A. PURPOSES AND LIMITATIONS 4 Discovery in this action is likely to involve production of confidential, 5 proprietary, or private information for which special protection from public 6 disclosure and from use for any purpose other than prosecuting this litigation may 7 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 8 enter the following Stipulated Protective Order. The parties acknowledge that this 9 Order does not confer blanket protections on all disclosures or responses to 10 discovery and that the protection it affords from public disclosure and use extends 11 only to the limited information or items that are entitled to confidential treatment 12 under the applicable legal principles. The parties further acknowledge, as set forth 13 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 14 file confidential information under seal; Civil Local Rule 79-5 sets forth the 15 procedures that must be followed and the standards that will be applied when a 16 party seeks permission from the court to file material under seal. 17 B. GOOD CAUSE STATEMENT 18 This action is likely to involve trade secrets, customer and pricing lists and 19 other valuable proprietary information for which special protection from public 20 disclosure and from use for any purpose other than prosecution of this action is 21 warranted. Such confidential and proprietary materials and information consist of, 22 among other things, sales summaries, pricing, internal business strategies, and 23 other confidential business or financial information, or information regarding 24 confidential business practices. The confidential information at issue is generally 25 unavailable to the public and may be privileged or otherwise protected from 26 disclosure under state or federal statutes, court rules, case decisions, or common 27 law. 28 -2PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 1 Accordingly, to expedite the flow of information, to facilitate the prompt 2 resolution of disputes over confidentiality of discovery materials, to adequately 3 protect information the parties are entitled to keep confidential, to ensure that the 4 parties are permitted reasonable necessary uses of such material in preparation for 5 and in the conduct of trial, to address their handling at the end of the litigation, and 6 serve the ends of justice, a protective order for such information is justified in this 7 matter. It is the intent of the parties that information will not be designated as 8 confidential for tactical reasons and that nothing be so designated without a good 9 faith belief that it has been maintained in a confidential, non-public manner, and 10 there is good cause why it should not be part of the public record of this case. 11 2. DEFINITIONS 12 2.1 Action: this pending federal law suit. 13 2.2 Challenging Party: a Party or Non-Party that challenges the 14 15 designation of information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 16 how it is generated, stored or maintained) or tangible things that qualify for 17 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 18 the Good Cause Statement. 19 20 21 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 22 items that it produces in disclosures or in responses to discovery as 23 “CONFIDENTIAL.” 24 2.6 Disclosure or Discovery Material: all items or information, regardless 25 of the medium or manner in which it is generated, stored, or maintained (including, 26 among other things, testimony, transcripts, and tangible things), that are produced 27 or generated in disclosures or responses to discovery in this matter. 28 -3PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 2.7 1 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as 3 an expert witness or as a consultant in this Action. 2.8 4 “HIGHLY CONFIDENTIAL” or “ATTORNEY EYES ONLY” 5 Information or Items: information (regardless of how it is generated, stored or 6 maintained) or tangible things that qualify for protection under Federal Rule of 7 Civil Procedure 26(c), and as specified above in the Good Cause Statement for 8 which disclosures to another party is likely to result in harm to the Designating 9 Party. 10 2.9 House Counsel: attorneys who are employees of a party to this Action. 11 House Counsel does not include Outside Counsel of Record or any other outside 12 counsel. 13 14 2.10 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 15 2.11 Outside Counsel of Record: attorneys who are not employees of a 16 party to this Action but are retained to represent or advise a party to this Action and 17 have appeared in this Action on behalf of that party or are affiliated with a law firm 18 that has appeared on behalf of that party, including support staff. 19 2.12 Party: any party to this Action, including all of its officers, directors, 20 employees, consultants, retained experts, and Outside Counsel of Record (and their 21 support staffs). 22 23 2.13 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 24 2.14 Professional Vendors: persons or entities that provide litigation 25 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 26 demonstrations, and organizing, storing, or retrieving data in any form or medium) 27 and their employees and subcontractors. 28 -4PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 1 2.15 Protected Material: any Disclosure or Discovery Material that is 2 designated 3 “ATTORNEY EYES ONLY.” 4 5 as “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party. 6 3. 7 The protections conferred by this Stipulation and Order cover not only 8 Protected Material (as defined above), but also (1) any information copied or 9 extracted from Protected Material; (2) all copies, excerpts, summaries, or 10 compilations of Protected Material; and (3) any testimony, conversations, or 11 presentations by Parties or their Counsel that might reveal Protected Material. 12 13 SCOPE Any use of Protected Material at trial shall be governed by the orders of the trial judge. This Order does not govern the use of Protected Material at trial. 14 4. DURATION 15 Once a case proceeds to trial, all of the court-filed information to be 16 introduced that was previously designated as confidential or maintained pursuant to 17 this protective order becomes public and will be presumptively available to all 18 members of the public, including the press, unless compelling reasons supported by 19 specific factual findings to proceed otherwise are made to the trial judge in advance 20 of the trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180- 21 81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents 22 produced in discovery from “compelling reasons” standard when merits-related 23 documents are part of court record). Accordingly, the terms of this protective order 24 do not extend beyond the commencement of the trial. 25 5. DESIGNATING PROTECTED MATERIAL 26 5.1 Exercise of Restraint and Care in Designating Material for Protection. 27 28 Each Party or Non-Party that designates information or items for protection under -5PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 1 this Order must take care to limit any such designation to specific material that 2 qualifies under the appropriate standards. The Designating Party must designate for 3 protection only those parts of material, documents, items, or oral or written 4 communications that qualify so that other portions of the material, documents, 5 items, or communications for which protection is not warranted are not swept 6 unjustifiably within the ambit of this Order. 7 Mass, indiscriminate, or routinized designations are prohibited. Designations 8 that are shown to be clearly unjustified or that have been made for an improper 9 purpose (e.g., to unnecessarily encumber the case development process or to 10 impose unnecessary expenses and burdens on other parties) may expose the 11 Designating Party to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 5.2 Manner and Timing of Designations. Except as otherwise provided in 16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 18 under this Order must be clearly so designated before the material is disclosed or 19 produced. 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic 22 documents, but excluding transcripts of depositions or other pretrial or trial 23 proceedings), that the Producing Party affix, at a minimum, the legend 24 “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “ATTORNEY EYES 25 ONLY” (hereinafter “CONFIDENTIAL legend”), to each page that contains 26 protected material. If only a portion or portions of the material on a page qualifies 27 28 -6PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 1 for protection, the Producing Party also must clearly identify the protected 2 portion(s) (e.g., by making appropriate markings in the margins). 3 A Party or Non-Party that makes original documents available for inspection 4 need not designate them for protection until after the inspecting Party has indicated 5 which documents it would like copied and produced. During the inspection and 6 before the designation, all of the material made available for inspection shall be 7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 8 documents it wants copied and produced, the Producing Party must determine 9 which documents, or portions thereof, qualify for protection under this Order. 10 Then, before producing the specified documents, the Producing Party must affix 11 the “CONFIDENTIAL legend” to each page that contains Protected Material. If 12 only a portion or portions of the material on a page qualifies for protection, the 13 Producing Party also must clearly identify the protected portion(s) (e.g., by making 14 appropriate markings in the margins). 15 (b) for testimony given in depositions that the Designating Party identify 16 the Disclosure or Discovery Material on the record, before the close of the 17 deposition. 18 (c) for information produced in some form other than documentary and 19 for any other tangible items, that the Producing Party affix in a prominent place on 20 the exterior of the container or containers in which the information is stored the 21 legend “CONFIDENTIAL.” If only a portion or portions of the information 22 warrants protection, the Producing Party, to the extent practicable, shall identify the 23 protected portion(s). 24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 25 failure to designate qualified information or items does not, standing alone, waive 26 the Designating Party’s right to secure protection under this Order for such 27 material. Upon timely correction of a designation, the Receiving Party must make 28 -7PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 1 reasonable efforts to assure that the material is treated in accordance with the 2 provisions of this Order. 3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 5 designation of confidentiality at any time that is consistent with the Court’s 6 Scheduling Order. 7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 8 resolution process under Local Rule 37.1, et seq. Any discovery motion must 9 strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 10 6.3 Burden. The burden of persuasion in any such challenge proceeding 11 shall be on the Designating Party. Frivolous challenges, and those made for an 12 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 13 other parties) may expose the Challenging Party to sanctions. Unless the 14 Designating Party has waived or withdrawn the confidentiality designation, all 15 parties shall continue to afford the material in question the level of protection to 16 which it is entitled under the Producing Party’s designation until the Court rules on 17 the challenge. 18 19 7. ACCESS TO AND USE OF PROTECTED MATERIAL 20 7.1 Basic Principles. A Receiving Party may use Protected Material that is 21 disclosed or produced by another Party or by a Non-Party in connection with this 22 Action only for prosecuting, defending, or attempting to settle this Action. Such 23 Protected Material may be disclosed only to the categories of persons and under the 24 conditions described in this Order. When the Action has been terminated, a 25 Receiving Party must comply with the provisions of section 13 below (FINAL 26 DISPOSITION). Protected Material must be stored and maintained by a Receiving 27 28 -8PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 1 Party at a location and in a secure manner that ensures that access is limited to the 2 persons authorized under this Order. 3 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 4 otherwise ordered by the Court or permitted in writing by the Designating Party, a 5 Receiving 6 “CONFIDENTIAL” only to: 7 (a) Party may disclose any information or item designated the Receiving Party’s Outside Counsel of Record in this Action, as 8 well as employees of said Outside Counsel of Record to whom it is reasonably 9 necessary to disclose the information for this Action; 10 11 12 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; (c) Experts (as defined in this Order) of the Receiving Party to whom 13 disclosure is reasonably necessary for this Action and who have signed the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (d) the Court and its personnel; 16 (e) court reporters and their staff; 17 (f) professional jury or trial consultants, mock jurors, and Professional 18 Vendors to whom disclosure is reasonably necessary for this Action and who have 19 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 21 22 (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 23 Action to whom disclosure is reasonably necessary provided: (1) the deposing 24 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 25 they will not be permitted to keep any confidential information unless they sign the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 27 agreed by the Designating Party or ordered by the Court. Pages of transcribed 28 -9PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 1 deposition testimony or exhibits to depositions that reveal Protected Material may 2 be separately bound by the court reporter and may not be disclosed to anyone 3 except as permitted under this Stipulated Protective Order; and 4 5 6 (i) any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 7.3 Disclosure of “HIGHLY CONFIDENTIAL” or “HIGHLY 7 CONFIDENTIAL – ATTORNEY’S EYES ONLY” Information or Items. Unless 8 otherwise ordered by the court or permitted in writing by the Designating Party, a 9 Receiving Party may disclose any information or item designated “HIGHLY 10 11 CONFIDENTIAL” or “ATTORNEY EYES ONLY” only to: (a) the Receiving Party’s Outside Counsel of Record in this Action, as 12 well as employees of said Outside Counsel of Record to whom it is reasonably 13 necessary to disclose the information for this Action. 14 (b) Experts (as defined in this Order) of the Receiving Party to whom 15 disclosure is reasonably necessary for this Action and who have signed the 16 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (c) the court and its personnel; 18 (d) court reporters and their staff; 19 (e) professional jury or trial consultants, mock jurors, and Professional 20 Vendors to whom disclosure is reasonably necessary for this Action and who have 21 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 22 23 24 25 26 27 28 (f) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; and (g) any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. Notwithstanding the terms of this section, a designation by Defendants that certain materials are “HIGHLY CONFIDENTIAL” - 10 PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION or “HIGHLY 1 CONFIDENTIAL – ATTORNEY’S EYES ONLY” shall not preclude Plaintiff’s 2 attorney from disclosing to an officer of Plaintiff with settlement authority the total 3 revenue and gross profits of a defendant as set forth in such material, so long as 4 Plaintiff’s attorney does not disclose the designated document itself. This section 5 shall also not preclude Plaintiff’s attorney from disclosing to an officer of Plaintiff 6 with settlement authority the names of any parties identified in materials designated 7 as 8 ATTORNEY’S EYES ONLY” and not otherwise disclosed in this Action who 9 distributed product which is alleged to infringe Plaintiff’s alleged copyright. 10 11 “HIGHLY 8. CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 12 If a Party is served with a subpoena or a court order issued in other litigation 13 that compels disclosure of any information or items designated in this Action as 14 “CONFIDENTIAL,” that Party must: 15 16 17 (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 18 to issue in the other litigation that some or all of the material covered by the 19 subpoena or order is subject to this Protective Order. Such notification shall include 20 a copy of this Stipulated Protective Order; and 21 22 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 23 If the Designating Party timely seeks a protective order, the Party served 24 with the subpoena or court order shall not produce any information designated in 25 this action as “CONFIDENTIAL” before a determination by the court from which 26 the subpoena or order issued, unless the Party has obtained the Designating Party’s 27 permission. The Designating Party shall bear the burden and expense of seeking 28 - 11 PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 1 protection in that court of its confidential material and nothing in these provisions 2 should be construed as authorizing or encouraging a Receiving Party in this Action 3 to disobey a lawful directive from another court. 4 5 6 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION (a) The terms of this Order are applicable to information produced by a 7 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 8 produced by Non-Parties in connection with this litigation is protected by the 9 remedies and relief provided by this Order. Nothing in these provisions should be 10 11 construed as prohibiting a Non-Party from seeking additional protections. (b) In the event that a Party is required, by a valid discovery request, to 12 produce a NonParty’s confidential information in its possession, and the Party is 13 subject to an agreement with the Non-Party not to produce the Non-Party’s 14 confidential information, then the Party shall: 15 (1) promptly notify in writing the Requesting Party and the Non-Party that 16 some or all of the information requested is subject to a confidentiality agreement 17 with a Non-Party; 18 (2) promptly provide the Non-Party with a copy of the Stipulated 19 Protective Order in this Action, the relevant discovery request(s), and a reasonably 20 specific description of the information requested; and 21 22 23 (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 24 14 days of receiving the notice and accompanying information, the Receiving Party 25 may produce the NonParty’s confidential information responsive to the discovery 26 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 27 not produce any information in its possession or control that is subject to the 28 - 12 PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 1 confidentiality agreement with the Non-Party before a determination by the Court. 2 Absent a court order to the contrary, the Non-Party shall bear the burden and 3 expense of seeking protection in this Court of its Protected Material. 10. 4 5 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 6 If a Receiving Party learns that, by inadvertence or otherwise, it has 7 disclosed Protected Material to any person or in any circumstance not authorized 8 under this Stipulated Protective Order, the Receiving Party must immediately (a) 9 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 10 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 11 the person or persons to whom unauthorized disclosures were made of all the terms 12 of this Order, and (d) request such person or persons to execute the 13 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 14 A. 15 16 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL 17 When a Producing Party gives notice to Receiving Parties that certain 18 inadvertently produced material is subject to a claim of privilege or other 19 protection, the obligations of the Receiving Parties are those set forth in Federal 20 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 21 whatever procedure may be established in an e-discovery order that provides for 22 production without prior privilege review. Pursuant to Federal Rule of Evidence 23 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 24 of a communication or information covered by the attorney-client privilege or work 25 product protection, the parties may incorporate their agreement in the stipulated 26 protective order submitted to the Court. 27 28 12. MISCELLANEOUS - 13 PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 1 2 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. 3 12.2 Right to Assert Other Objections. By stipulating to the entry of this 4 Protective Order, no Party waives any right it otherwise would have to object to 5 disclosing or producing any information or item on any ground not addressed in 6 this Stipulated Protective Order. Similarly, no Party waives any right to object on 7 any ground to use in evidence of any of the material covered by this Protective 8 Order. 9 12.3 Filing Protected Material. A Party that seeks to file under seal any 10 Protected Material must comply with Civil Local Rule 79-5. Protected Material 11 may only be filed under seal pursuant to a court order authorizing the sealing of the 12 specific Protected Material at issue; good cause must be shown in the request to file 13 under seal. If a Party’s request to file Protected Material under seal is denied by the 14 Court, then the Receiving Party may file the information in the public record unless 15 otherwise instructed by the Court. 16 13. 17 After the final disposition of this Action, within 60 days of a written request 18 by the Designating Party, each Receiving Party must return all Protected Material 19 to the Producing Party or destroy such material. As used in this subdivision, “all 20 Protected Material” includes all copies, abstracts, compilations, summaries, and 21 any other format reproducing or capturing any of the Protected Material. Whether 22 the Protected Material is returned or destroyed, the Receiving Party must submit a 23 written certification to the Producing Party (and, if not the same person or entity, to 24 the Designating Party) by the 60 day deadline that (1) identifies (by category, 25 where appropriate) all the Protected Material that was returned or destroyed and (2) 26 affirms that the Receiving Party has not retained any copies, abstracts, 27 compilations, summaries or any other format reproducing or capturing any of the 28 FINAL DISPOSITION - 14 PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 1 Protected Material. Notwithstanding this provision, counsel are entitled to retain an 2 archival copy of all pleadings, motion papers, trial, deposition, and hearing 3 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 4 reports, attorney work product, and consultant and expert work product, even if 5 such materials contain Protected Material. Any such archival copies that contain or 6 constitute Protected Material remain subject to this Protective Order as set forth in 7 Section 4 (DURATION). 8 14. Any violation of this Order may be punished by any and all appropriate 9 measures including, without limitation, contempt proceedings and/or monetary 10 sanctions. 11 12 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 13 14 15 Dated: September 5, 2018 By: 16 17 ____________________________ Honorable Paul L. Abrams United States Magistrate Judge 18 19 20 21 22 23 24 25 26 27 28 - 15 PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 in the case of Gold Value International Textile, Inc. v. Zara USA, Inc., et al. Case 8 No. 2:17-cv-08226-DSF-PLA. I agree to comply with and to be bound by all the 9 terms of this Stipulated Protective Order and I understand and acknowledge that 10 failure to so comply could expose me to sanctions and punishment in the nature of 11 contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Stipulated Protective Order to any person 13 or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District 15 Court for the Central District of California for the purpose of enforcing the terms of 16 this Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination 18 _____________________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ of this action. I hereby 24 25 Printed name: _______________________________ 26 Signature: __________________________________ 27 28 - 16 PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION appoint

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