First American Cinema, LLC v. Screen Media Ventures LLC et al

Filing 71

STIPULATED PROTECTIVE ORDER by Magistrate Judge Michael R. Wilner. (SEE PROTECTIVE ORDER FOR FURTHER DETAILS) 69 (yl)

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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10 FIRST AMERICAN CINEMA, LLC, a
California limited liability company,
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Plaintiff,

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Assignedfor all purposes to the
Honorable Judge George H. WuJ

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Case No.: 2:18-cv-03703-GHW-MRW

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Screen Media Ventures, LLC, et al.,
ROTECTI
Defendants

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STIPULATED
ORDER

1.

INTRODUCTION

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1.1. 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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0 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

22 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

27 in Section 12.3, below, that this Stipulated Protective Order does not entitle them
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to file confidential information under seal; Civil Local Rule 79-5 sets forth the

[
PROPOSED] STIPULATED PROTECTIVE ORDER

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procedures that must be followed and the standards that will be applied when a

2 party seeks permission from the court.to file material under seal.
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1.2. GOOD CAUSE STATEMENT

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This action involves confidential license and distribution agreements, data, and

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information for which special protection from public disclosure and from use for

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any purpose other than prosecution of this action is warranted. Such confidential

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and proprietary materials and information consist of, among other things,

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confidential business or financial information, information regarding confidential

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business practices, or other commercial information (including information

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unavailable to the public, or which 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. 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 ofjustice, 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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22 there is good cause why it should not be part of the public record of this case.
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4 2.

DEFINITIONS

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2.1.

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Action: First American Cinema, LLC v. Screen Media Ventures, LLC,

et al., Case No.: 2:18-cv-03703.
2.2.

Challen~inParty: a Party or Non-Party that challenges the

designation of information or items under this Order.
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STIPULATED PROTECTIVE ORDER

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2.3. "CONFIDENTIAL" Information or Items: information (regardless of

2 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

4 the Good Cause Statement.
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2.4.

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

6 their support staff.
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2.5.

Desi~nating,Party: a Party or Ikon-Party that designates information or

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

9 "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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pertinent to the litigation who has been retained by a Party or its counsel to serve

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as an expert witness or as a consultant in this Action.

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2.7.

2.8.

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

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

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

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counsel.

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2.9.

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

or other legal entity not named as a Party to this action.

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2.10. 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

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and have appeared in this Action on behalf ofthat party or are affiliated with a law

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

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

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

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support staffs).
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PROTECTIVE ORDER
STIPULATED

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2.12. Producing Party: a Party or Non-Party that produces Disclosure or

2 Discovery Material in this Action.
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2.13. 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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2.14. Protected Material: any Disclosure or Discovery Material that is
designated as "CONFIDENTIAL."

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2.15. Receiving Party: a Party that receives Disclosure or Discovery
Material from a Producing Party.

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3.

SCOPE

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

19 trial judge. This Order does not govern the use of Protected Material at trial.
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4.

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

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

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otherwise in writing or a court order otherwise directs. Final disposition will be

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deemed to be the later of(1) dismissal of all claims and defenses in this Action,

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with or without prejudice; and (2)final judgment herein after the completion and

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exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

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PROTECTIVE ORDER
STIPULATED

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including the time limits for filing any motions or applications for extension of

2 time pursuant to applicable law.
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4 5.

DESIGNATING PROTECTED 1VfATERIAL

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5.1.

Exercise of Restraint and Care in Desi nating Material for Protection.

6 Each Party or Non-Party that designates information or items for protection under
7 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

10 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

12 unjustifiably within the ambit of this Order.
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Mass, indiscriminate, or routinized designations are prohibited. Designations

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14 that are shown to be clearly unjustified or that have been made for an improper

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

purpose (e.g., to unnecessarily encumber the case development process or to

17 Designating Party to sanctions.
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If it comes to a Designating Party's attention that information or items that it

19 designated for protection do not qualify for protection, that Designating Party must
2 promptly notify all other Parties that it is withdrawing the inapplicable designation.
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5.2.

Manner and Timing of Desib.
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Except as otherwise provided in

22 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

24 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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STIPULATED PROTECTIVE ORDER

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

2 "CONFIDENTIAL"(hereinafter "CONFIDENTIAL legend"), to each page that
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contains protected material. If only a portion or portions of the material on a page

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

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protected portions)(e.g., by making appropriate markings in the margins).

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

7 inspection need not designate them for protection until after the inspecting Party
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has indicated which documents it would like copied and produced. During the

9 inspection and before the designation, all of the material made available for
10 inspection will be deemed "CONFIDENTIAL." After the inspecting Party has

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identified the documents it wants copied and produced, the Producing Party must

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determine which documents, or portions thereof, qualify for protection under this

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Order. Then, before producing the specified documents, the Producing Party must

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affix the "CONFIDENTIAL legend" to each page that contains Protected Material.

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If 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 portions)(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

19 the Disclosure or Discovery Material on the record, before the close ofthe
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deposition all protected testimony.
(c) for information produced in some form other than documentary and for

22 any other tangible items, that the Producing Party affix in a prominent place on the
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exterior ofthe container or containers in which the information is stored the legend

2 "CONFIDENTIAL." If only a portion or portions of the information warrants
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protection, the Producing Party, to the extent practicable, will identify the

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protected portion(s).

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5.3.

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

failure to designate qualified information or items does not, standing alone, waive
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STIPULATED PROTECTIVE ORDER

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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.

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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1.

Timing of ChallenLes. 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 will initiate the dispute

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resolution process (and, if necessary, file a discovery motion) under Local Rule

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37.1 et seq.

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the Designating Party. Frivolous challenges, and those made for an improper

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purpose (e.g., to harass or impose unnecessary expenses and burdens on other

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parties) may expose the Challenging Party to sanctions. Unless the Designating

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Party has waived or withdrawn the confidentiality designation, all parties will

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continue to afford the material in question the level of protection to which it is

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entitled under the Producing Party's designation until the Court rules on the

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challenge.

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6.3.

The burden of persuasion in any such challenge proceeding will be on

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7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1.

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

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

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

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

27 the conditions described in this Order. When the Action has been terminated, a
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STIPULATED PROTECTIVE ORDER

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Receiving Party must comply with the provisions of section 13 below (FINAL

2 DISPOSITION).
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Protected Material must be stored and maintained by a Receiving Party at a

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

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authorized under this Order.

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7.2.

Disclosure of"CONFIDENTIAL" Information or Items. Unless

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

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Receiving Party may disclose any information or item designated

9 "CONFIDENTIAL" only to:
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(a) the Receiving Party's Outside Counsel of Record in this Action, as

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

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necessary to disclose the information for this Action;

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(b) the officers, directors, and employees (including House Counsel) of
the Receiving Party to whom disclosure is reasonably necessary for this Action;

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

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

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"Acknowledgment and Agreement to Be Bound"(Exhibit A);

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(d) the Court and its personnel;

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(e) court reporters and their staff;

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(fl 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

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the 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 A hereto; and (2)

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they will not be permitted to keep any confidential information unless they sign
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STIPULATED PROTECTIVE ORDER

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the "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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( any mediator or settlement officer, and their supporting personnel,
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mutually agreed upon by any of the parties engaged in settlement discussions.

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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

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CONFIDENTIAL," that Party must:
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( promptly notify in writing the Designating Party. Such notification
a)
will include a copy of the subpoena or court order;
( promptly notify in writing the party who caused the subpoena or
b)

17 order 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 will include

19 a copy of this Stipulated Protective Order; and
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( cooperate with respect to all reasonable procedures sought to be
c)
pursued by the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served
with the subpoena or court order will not produce any information designated in

2 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

2 permission. The Designating Party will bear the burden and expense of seeking
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27 protection in that court of its confidential material and nothing in these provisions
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STIPULATED PROTECTIVE ORDER

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should be construed as authorizing or encouraging a Receiving Party in this Action

2 to disobey a lawful directive from another court.
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ANON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE

PRODUCED 1N 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 allon-Party from seeking additional protections.

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

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produce allon-Party's confidential information in its possession, and the Party is

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

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confidential information, then the Party will:

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

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

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agreement with allon-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

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

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Receiving Party may produce the Non-Party's confidential information responsive

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

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Receiving Party will not produce any information in its possession or control that

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is subject to the confidentiality agreement with the Non-Party before a
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STIPULATED PROTECTIVE ORDER

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determination by the court. Absent a court order to the contrary, the Non-Party

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will bear the burden and expense of seeking protection in this court of its

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Protected Material.

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10.

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

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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

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(a) notify in writing the Designating Party ofthe unauthorized disclosures,(b)use

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its best efforts to retrieve all unauthorized copies of the Protected Material,

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(c) inform the person or persons to whom unauthorized disclosures were made of

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all the terms 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

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Exhibit A.

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11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

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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

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work product protection, the parties may incorporate their agreement in the

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stipulated protective order submitted to the court.

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STIPULATED PROTECTIVE ORDER

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12.

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MISCELLANEOUS
12.1. Right to Further Relief. Nothing in this Order abridges the right of any

person to seek its modification by the Court in the future.

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

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

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

7 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

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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. If a Party's request to file Protected Material

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under seal is denied by the court, then the Receiving Party may file the information

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in the public record unless otherwise instructed by the court.

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13.

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

19 60 days of a written request by the Designating Party, each Receiving Party must
2 return all Protected Material to the Producing Party or destroy such material. As
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used in this subdivision,"all Protected Material" includes all copies, abstracts,

22 compilations, summaries, and any other format reproducing or capturing any ofthe
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Protected Material. Whether the Protected Material is returned or destroyed, the

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Receiving Party must submit a written certification to the Producing Party (and, if

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not the same person or entity, to the Designating Party) by the 60 day deadline that

2 (1) identifies(by category, where appropriate) all the Protected Material that was
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27 returned or destroyed and (2) affirms that the Receiving Party has not retained any
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copies, abstracts, compilations, summaries or any other format reproducing or
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STIPULATED PROTECTIVE ORDER

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capturing any ofthe Protected Material. Notwithstanding this provision, Counsel

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are entitled to retain an archival copy of all pleadings, motion papers, trial,

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deposition, and hearing transcripts, legal memoranda, correspondence, deposition

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and trial exhibits, expert reports, attorney~work product, and consultant and expert

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work product, even if such materials contain Protected Material. Any such archival

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copies that contain or constitute Protected Material remain subject to this

7 Protective Order as set forth in Section 4(DURATION).
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Any willful violation of this Order maybe punished by civil or criminal

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contempt proceedings, financial or evidentiary sanctions, reference to disciplinary

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authorities, or other appropriate action at the discretion ofthe Court.

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13 IT IS SO STIPULATED,THROUGH COUNSEL OF RECORD.
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15 DATED: April 1, 2019
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Respectfully submitted,
PESSAH LAW GROUP,PC

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By:

/s/Maurice D. Pessah
Maurice D. Pessah

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AttorneysfoY Plaintiff
First American Cinema, LLC

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22 DATED: April 1, 2019

NELSON MULLINS RILEY &
SCARBOROUGH LLP

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By: /s/Lauren A. Deeb
Lauren A. Deeb
Robert L. Hoegle
Attorneysfor Defendants
P
U Faith &Family, LLC and
Amazon.com, Inc.

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PROTECTIVE ORDER
STIPULATED

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2 DATED: April 1, 2019
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HAMRICK & EVANS,LLP
By: /s/Kenneth A. Kotarski
Martin J. Barab
A. Raymond Hamrick, III
Kenneth A. Kotarski
Jonathan Dutton
Attorneysfor Defendant
Crossclaimant, and CrossDefendant Screen Media Dentures,
LLC and Defendants Tribune
Media Company erroneously sued
as Tribune Media Company, Inc.
and WGN Continental
Broadcasting Company, LLC

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14 FOR GOOD CAUSE SHOWN,IT IS SO ORDERED.

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April 11, 2019
16 DATED:
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/s/ Judge Wilner
HON. MICHAEL R. WIENER
United States Magistrate Judge

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STIPULATED PROTECTIVE ORDER

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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[full name], of

I,

5 [
full address], declare under penalty of perjury that I have read in its entirety and
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understand the Stipulated Protective Order that was issued.by the United States

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District Court for the Central District of California on [date] in the case ofFirst

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American Cinema, LLC v. Screen Media Ventures, LLC, et al., Case No.: 2:18-cv-

9 03703. Iagree to comply with and to be bound by all the terms of this Stipulated
10 Protective Order and I understand and acknowledge that failure to so comply could
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expose me to sanctions and punishment in the nature of contempt. I solemnly

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promise that I will not disclose in any manner any information or item that is

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subject to this Stipulated Protective Order to any person or entity except in strict

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compliance with the provisions of this Order.

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Court for the Central District of California for the purpose of enforcing the terms

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of this Stipulated Protective Order, even if such enforcement proceedings occur

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after termination of this action. I hereby appoint

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name]of

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I further agree to submit to the jurisdiction of the United States District

[full
[full address and

2
0 telephone number] as my California agent for service of process in connection
21

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

2
2 Protective Order.
23

Date:

24

City and State where signed:

25
2
6 Printed name:
27
28

Signature:
is
STIPULATED PROTECTIVE ORDER