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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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
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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Case No.: 2:17-cv-08226-DSF-PLAx
Honorable Dale S. Fischer Presiding
Referred to Hon. Paul L. Abrams
GOLD VALUE INTERNATIONAL
TEXTILE, INC.,
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Plaintiff,
DISCOVERY MATTER
v.
PROTECTIVE ORDER
ZARA USA, INC.; et al.,
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Defendants.
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-1PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION
On stipulation of the Parties, the Court enters a Protective Order in this
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matter as follows:
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A.
PURPOSES AND LIMITATIONS
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Discovery in this action is likely to involve production of confidential,
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proprietary, or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may
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be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
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enter the following Stipulated Protective Order. The parties acknowledge that this
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Order does not confer blanket protections on all disclosures or responses to
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discovery and that the protection it affords from public disclosure and use extends
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only to the limited information or items that are entitled to confidential treatment
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under the applicable legal principles. The parties further acknowledge, as set forth
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in Section 12.3, below, that this Stipulated Protective Order does not entitle them to
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file confidential information under seal; Civil Local Rule 79-5 sets forth the
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procedures that must be followed and the standards that will be applied when a
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party seeks permission from the court to file material under seal.
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B.
GOOD CAUSE STATEMENT
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This action is likely to involve trade secrets, customer and pricing lists and
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other valuable proprietary information for which special protection from public
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disclosure and from use for any purpose other than prosecution of this action is
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warranted. Such confidential and proprietary materials and information consist of,
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among other things, sales summaries, pricing, internal business strategies, and
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other confidential business or financial information, or information regarding
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confidential business practices. The confidential information at issue is generally
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unavailable to the public and may be privileged or otherwise protected from
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disclosure under state or federal statutes, court rules, case decisions, or common
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law.
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-2PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION
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Accordingly, to expedite the flow of information, to facilitate the prompt
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resolution of disputes over confidentiality of discovery materials, to adequately
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protect information the parties are entitled to keep confidential, to ensure that the
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parties are permitted reasonable necessary uses of such material in preparation for
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and in the conduct of trial, to address their handling at the end of the litigation, and
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serve the ends of justice, a protective order for such information is justified in this
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matter. It is the intent of the parties that information will not be designated as
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confidential for tactical reasons and that nothing be so designated without a good
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faith belief that it has been maintained in a confidential, non-public manner, and
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there is good cause why it should not be part of the public record of this case.
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2.
DEFINITIONS
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2.1
Action: this pending federal law suit.
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2.2
Challenging Party: a Party or Non-Party that challenges the
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designation of information or items under this Order.
2.3
“CONFIDENTIAL” Information or Items: information (regardless of
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how it is generated, stored or maintained) or tangible things that qualify for
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protection under Federal Rule of Civil Procedure 26(c), and as specified above in
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the Good Cause Statement.
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2.4
Counsel: Outside Counsel of Record and House Counsel (as well as
their support staff).
2.5
Designating Party: a Party or Non-Party that designates information or
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items that it produces in disclosures or in responses to discovery as
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“CONFIDENTIAL.”
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2.6
Disclosure or Discovery Material: all items or information, regardless
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of the medium or manner in which it is generated, stored, or maintained (including,
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among other things, testimony, transcripts, and tangible things), that are produced
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or generated in disclosures or responses to discovery in this matter.
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-3PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION
2.7
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Expert: a person with specialized knowledge or experience in a matter
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pertinent to the litigation who has been retained by a Party or its counsel to serve as
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an expert witness or as a consultant in this Action.
2.8
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“HIGHLY CONFIDENTIAL” or “ATTORNEY EYES ONLY”
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Information or Items: information (regardless of how it is generated, stored or
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maintained) or tangible things that qualify for protection under Federal Rule of
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Civil Procedure 26(c), and as specified above in the Good Cause Statement for
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which disclosures to another party is likely to result in harm to the Designating
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Party.
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2.9
House Counsel: attorneys who are employees of a party to this Action.
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House Counsel does not include Outside Counsel of Record or any other outside
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counsel.
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2.10 Non-Party: any natural person, partnership, corporation, association,
or other legal entity not named as a Party to this action.
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2.11 Outside Counsel of Record: attorneys who are not employees of a
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party to this Action but are retained to represent or advise a party to this Action and
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have appeared in this Action on behalf of that party or are affiliated with a law firm
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that has appeared on behalf of that party, including support staff.
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2.12 Party: any party to this Action, including all of its officers, directors,
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employees, consultants, retained experts, and Outside Counsel of Record (and their
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support staffs).
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2.13 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
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2.14 Professional Vendors: persons or entities that provide litigation
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support services (e.g., photocopying, videotaping, translating, preparing exhibits or
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demonstrations, and organizing, storing, or retrieving data in any form or medium)
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and their employees and subcontractors.
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-4PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION
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2.15 Protected Material: any Disclosure or Discovery Material that is
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designated
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“ATTORNEY EYES ONLY.”
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as
“CONFIDENTIAL,”
“HIGHLY
CONFIDENTIAL,”
or
2.16 Receiving Party: a Party that receives Disclosure or Discovery
Material from a Producing Party.
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3.
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The protections conferred by this Stipulation and Order cover not only
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Protected Material (as defined above), but also (1) any information copied or
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extracted from Protected Material; (2) all copies, excerpts, summaries, or
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compilations of Protected Material; and (3) any testimony, conversations, or
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presentations by Parties or their Counsel that might reveal Protected Material.
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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.
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4.
DURATION
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Once a case proceeds to trial, all of the court-filed information to be
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introduced that was previously designated as confidential or maintained pursuant to
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this protective order becomes public and will be presumptively available to all
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members of the public, including the press, unless compelling reasons supported by
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specific factual findings to proceed otherwise are made to the trial judge in advance
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of the trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-
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81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents
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produced in discovery from “compelling reasons” standard when merits-related
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documents are part of court record). Accordingly, the terms of this protective order
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do not extend beyond the commencement of the trial.
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5.
DESIGNATING PROTECTED MATERIAL
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5.1
Exercise of Restraint and Care in Designating Material for Protection.
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Each Party or Non-Party that designates information or items for protection under
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this Order must take care to limit any such designation to specific material that
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qualifies under the appropriate standards. The Designating Party must designate for
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protection only those parts of material, documents, items, or oral or written
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communications that qualify so that other portions of the material, documents,
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items, or communications for which protection is not warranted are not swept
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unjustifiably within the ambit of this Order.
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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
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purpose (e.g., to unnecessarily encumber the case development process or to
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impose unnecessary expenses and burdens on other parties) may expose the
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Designating Party to sanctions.
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If it comes to a Designating Party’s attention that information or items that it
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designated for protection do not qualify for protection, that Designating Party must
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promptly notify all other Parties that it is withdrawing the inapplicable designation.
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5.2
Manner and Timing of Designations. Except as otherwise provided in
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this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
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stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
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under this Order must be clearly so designated before the material is disclosed or
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produced.
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Designation in conformity with this Order requires:
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(a)
for information in documentary form (e.g., paper or electronic
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documents, but excluding transcripts of depositions or other pretrial or trial
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proceedings), that the Producing Party affix, at a minimum, the legend
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“CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “ATTORNEY EYES
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ONLY” (hereinafter “CONFIDENTIAL legend”), to each page that contains
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protected material. If only a portion or portions of the material on a page qualifies
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for protection, the Producing Party also must clearly identify the protected
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portion(s) (e.g., by making appropriate markings in the margins).
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A Party or Non-Party that makes original documents available for inspection
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need not designate them for protection until after the inspecting Party has indicated
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which documents it would like copied and produced. During the inspection and
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before the designation, all of the material made available for inspection shall be
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deemed “CONFIDENTIAL.” After the inspecting Party has identified the
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documents it wants copied and produced, the Producing Party must determine
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which documents, or portions thereof, qualify for protection under this Order.
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Then, before producing the specified documents, the Producing Party must affix
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the “CONFIDENTIAL legend” to each page that contains Protected Material. If
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only a portion or portions of the material on a page qualifies for protection, the
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Producing Party also must clearly identify the protected portion(s) (e.g., by making
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appropriate markings in the margins).
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(b)
for testimony given in depositions that the Designating Party identify
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the Disclosure or Discovery Material on the record, before the close of the
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deposition.
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(c)
for information produced in some form other than documentary and
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for any other tangible items, that the Producing Party affix in a prominent place on
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the exterior of the container or containers in which the information is stored the
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legend “CONFIDENTIAL.” If only a portion or portions of the information
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warrants protection, the Producing Party, to the extent practicable, shall identify the
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protected portion(s).
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5.3
Inadvertent Failures to Designate. If timely corrected, an inadvertent
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failure to designate qualified information or items does not, standing alone, waive
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the Designating Party’s right to secure protection under this Order for such
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material. Upon timely correction of a designation, the Receiving Party must make
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reasonable efforts to assure that the material is treated in accordance with the
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provisions of this Order.
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6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
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6.1
Timing of Challenges. Any Party or Non-Party may challenge a
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designation of confidentiality at any time that is consistent with the Court’s
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Scheduling Order.
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6.2
Meet and Confer. The Challenging Party shall initiate the dispute
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resolution process under Local Rule 37.1, et seq. Any discovery motion must
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strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
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6.3
Burden. The burden of persuasion in any such challenge proceeding
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shall be on the Designating Party. Frivolous challenges, and those made for an
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improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
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other parties) may expose the Challenging Party to sanctions. Unless the
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Designating Party has waived or withdrawn the confidentiality designation, all
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parties shall continue to afford the material in question the level of protection to
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which it is entitled under the Producing Party’s designation until the Court rules on
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the challenge.
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7.
ACCESS TO AND USE OF PROTECTED MATERIAL
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7.1 Basic Principles. A Receiving Party may use Protected Material that is
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disclosed or produced by another Party or by a Non-Party in connection with this
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Action only for prosecuting, defending, or attempting to settle this Action. Such
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Protected Material may be disclosed only to the categories of persons and under the
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conditions described in this Order. When the Action has been terminated, a
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Receiving Party must comply with the provisions of section 13 below (FINAL
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DISPOSITION). Protected Material must be stored and maintained by a Receiving
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Party at a location and in a secure manner that ensures that access is limited to the
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persons authorized under this Order.
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7.2
Disclosure of “CONFIDENTIAL” Information or Items. Unless
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otherwise ordered by the Court or permitted in writing by the Designating Party, a
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Receiving
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“CONFIDENTIAL” only to:
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(a)
Party
may
disclose
any
information
or
item
designated
the Receiving Party’s Outside Counsel of Record in this Action, as
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well as employees of said Outside Counsel of Record to whom it is reasonably
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necessary to disclose the information for this Action;
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(b)
the officers, directors, and employees (including House Counsel) of
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
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disclosure is reasonably necessary for this Action and who have signed the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(d)
the Court and its personnel;
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(e)
court reporters and their staff;
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(f)
professional jury or trial consultants, mock jurors, and Professional
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Vendors to whom disclosure is reasonably necessary for this Action and who have
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signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(g)
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
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Action to whom disclosure is reasonably necessary provided: (1) the deposing
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party requests that the witness sign the form attached as Exhibit 1 hereto; and (2)
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they will not be permitted to keep any confidential information unless they sign the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
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agreed by the Designating Party or ordered by the Court. Pages of transcribed
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deposition testimony or exhibits to depositions that reveal Protected Material may
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be separately bound by the court reporter and may not be disclosed to anyone
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except as permitted under this Stipulated Protective Order; and
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(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
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CONFIDENTIAL – ATTORNEY’S EYES ONLY” Information or Items. Unless
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otherwise ordered by the court or permitted in writing by the Designating Party, a
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Receiving Party may disclose any information or item designated “HIGHLY
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CONFIDENTIAL” or “ATTORNEY EYES ONLY” only to:
(a)
the Receiving Party’s Outside Counsel of Record in this Action, as
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well as employees of said Outside Counsel of Record to whom it is reasonably
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necessary to disclose the information for this Action.
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(b)
Experts (as defined in this Order) of the Receiving Party to whom
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disclosure is reasonably necessary for this Action and who have signed the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(c)
the court and its personnel;
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(d)
court reporters and their staff;
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(e)
professional jury or trial consultants, mock jurors, and Professional
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Vendors to whom disclosure is reasonably necessary for this Action and who have
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signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(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”
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or
“HIGHLY
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CONFIDENTIAL – ATTORNEY’S EYES ONLY” shall not preclude Plaintiff’s
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attorney from disclosing to an officer of Plaintiff with settlement authority the total
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revenue and gross profits of a defendant as set forth in such material, so long as
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Plaintiff’s attorney does not disclose the designated document itself. This section
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shall also not preclude Plaintiff’s attorney from disclosing to an officer of Plaintiff
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with settlement authority the names of any parties identified in materials designated
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as
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ATTORNEY’S EYES ONLY” and not otherwise disclosed in this Action who
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distributed product which is alleged to infringe Plaintiff’s alleged copyright.
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“HIGHLY
8.
CONFIDENTIAL”
or
“HIGHLY
CONFIDENTIAL
–
PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED IN OTHER LITIGATION
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If a Party is served with a subpoena or a court order issued in other litigation
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that compels disclosure of any information or items designated in this Action as
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“CONFIDENTIAL,” that Party must:
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(a)
promptly notify in writing the Designating Party. Such notification
shall include a copy of the subpoena or court order;
(b)
promptly notify in writing the party who caused the subpoena or order
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to issue in the other litigation that some or all of the material covered by the
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subpoena or order is subject to this Protective Order. Such notification shall include
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a copy of this Stipulated Protective Order; and
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(c)
cooperate with respect to all reasonable procedures sought to be
pursued by the Designating Party whose Protected Material may be affected.
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If the Designating Party timely seeks a protective order, the Party served
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with the subpoena or court order shall not produce any information designated in
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this action as “CONFIDENTIAL” before a determination by the court from which
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the subpoena or order issued, unless the Party has obtained the Designating Party’s
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permission. The Designating Party shall bear the burden and expense of seeking
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protection in that court of its confidential material and nothing in these provisions
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should be construed as authorizing or encouraging a Receiving Party in this Action
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to disobey a lawful directive from another court.
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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
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Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
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produced by Non-Parties in connection with this litigation is protected by the
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remedies and relief provided by this Order. Nothing in these provisions should be
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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
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produce a NonParty’s confidential information in its possession, and the Party is
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subject to an agreement with the Non-Party not to produce the Non-Party’s
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confidential information, then the Party shall:
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(1)
promptly notify in writing the Requesting Party and the Non-Party that
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some or all of the information requested is subject to a confidentiality agreement
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with a Non-Party;
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(2)
promptly provide the Non-Party with a copy of the Stipulated
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Protective Order in this Action, the relevant discovery request(s), and a reasonably
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specific description of the information requested; and
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(3)
make the information requested available for inspection by the Non-
Party, if requested.
(c)
If the Non-Party fails to seek a protective order from this Court within
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14 days of receiving the notice and accompanying information, the Receiving Party
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may produce the NonParty’s confidential information responsive to the discovery
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request. If the Non-Party timely seeks a protective order, the Receiving Party shall
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not produce any information in its possession or control that is subject to the
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confidentiality agreement with the Non-Party before a determination by the Court.
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Absent a court order to the contrary, the Non-Party shall bear the burden and
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expense of seeking protection in this Court of its Protected Material.
10.
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UNAUTHORIZED
DISCLOSURE
OF
PROTECTED
MATERIAL
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If a Receiving Party learns that, by inadvertence or otherwise, it has
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disclosed Protected Material to any person or in any circumstance not authorized
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under this Stipulated Protective Order, the Receiving Party must immediately (a)
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notify in writing the Designating Party of the unauthorized disclosures, (b) use its
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best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
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the person or persons to whom unauthorized disclosures were made of all the terms
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of this Order, and (d) request such person or persons to execute the
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“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
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A.
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11.
INADVERTENT
PRODUCTION
OF
PRIVILEGED
OR
OTHERWISE PROTECTED MATERIAL
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When a Producing Party gives notice to Receiving Parties that certain
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inadvertently produced material is subject to a claim of privilege or other
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protection, the obligations of the Receiving Parties are those set forth in Federal
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Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
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whatever procedure may be established in an e-discovery order that provides for
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production without prior privilege review. Pursuant to Federal Rule of Evidence
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502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
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of a communication or information covered by the attorney-client privilege or work
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product protection, the parties may incorporate their agreement in the stipulated
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protective order submitted to the Court.
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12.
MISCELLANEOUS
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12.1 Right to Further Relief. Nothing in this Order abridges the right of any
person to seek its modification by the Court in the future.
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12.2 Right to Assert Other Objections. By stipulating to the entry of this
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Protective Order, no Party waives any right it otherwise would have to object to
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disclosing or producing any information or item on any ground not addressed in
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this Stipulated Protective Order. Similarly, no Party waives any right to object on
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any ground to use in evidence of any of the material covered by this Protective
8
Order.
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12.3 Filing Protected Material. A Party that seeks to file under seal any
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Protected Material must comply with Civil Local Rule 79-5. Protected Material
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may only be filed under seal pursuant to a court order authorizing the sealing of the
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specific Protected Material at issue; good cause must be shown in the request to file
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under seal. If a Party’s request to file Protected Material under seal is denied by the
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Court, then the Receiving Party may file the information in the public record unless
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otherwise instructed by the Court.
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13.
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After the final disposition of this Action, within 60 days of a written request
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by the Designating Party, each Receiving Party must return all Protected Material
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to the Producing Party or destroy such material. As used in this subdivision, “all
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Protected Material” includes all copies, abstracts, compilations, summaries, and
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any other format reproducing or capturing any of the Protected Material. Whether
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the Protected Material is returned or destroyed, the Receiving Party must submit a
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written certification to the Producing Party (and, if not the same person or entity, to
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the Designating Party) by the 60 day deadline that (1) identifies (by category,
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where appropriate) all the Protected Material that was returned or destroyed and (2)
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affirms that the Receiving Party has not retained any copies, abstracts,
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compilations, summaries or any other format reproducing or capturing any of the
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FINAL DISPOSITION
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Protected Material. Notwithstanding this provision, counsel are entitled to retain an
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archival copy of all pleadings, motion papers, trial, deposition, and hearing
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transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
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reports, attorney work product, and consultant and expert work product, even if
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such materials contain Protected Material. Any such archival copies that contain or
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constitute Protected Material remain subject to this Protective Order as set forth in
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Section 4 (DURATION).
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14. Any violation of this Order may be punished by any and all appropriate
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measures including, without limitation, contempt proceedings and/or monetary
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sanctions.
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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Dated: September 5, 2018
By:
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____________________________
Honorable Paul L. Abrams
United States Magistrate Judge
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- 15 PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I, _____________________________ [print or type full name], of
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_________________ [print or type full address], declare under penalty of perjury
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that I have read in its entirety and understand the Stipulated Protective Order that
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was issued by the United States District Court for the Central District of California
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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
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terms of this Stipulated Protective Order and I understand and acknowledge that
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failure to so comply could expose me to sanctions and punishment in the nature of
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contempt. I solemnly promise that I will not disclose in any manner any
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information or item that is subject to this Stipulated Protective Order to any person
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or entity except in strict compliance with the provisions of this Order.
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I further agree to submit to the jurisdiction of the United States District
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Court for the Central District of California for the purpose of enforcing the terms of
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this Stipulated Protective Order, even if such enforcement proceedings occur after
17
termination
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_____________________________________ [print or type full name] of
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_______________________________________ [print or type full address and
20
telephone number] as my California agent for service of process in connection with
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this action or any proceedings related to enforcement of this Stipulated Protective
22
Order. Date: ______________________________________
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City and State where sworn and signed: _________________________________
of
this
action.
I
hereby
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Printed name: _______________________________
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Signature: __________________________________
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- 16 PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION
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