Carly Lemmon et al v. Snap, Inc.

Filing 96

PROTECTIVE ORDER by Magistrate Judge Karen L. Stevenson re Stipulation for Protective Order 95 . (see document for details) (hr)

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1 JONATHAN H. BLAVIN (SBN 230269) 2 MUNGER, TOLLES & OLSON LLP 560 Mission Street, Twenty-Seventh Floor 3 San Francisco, California 94105-2907 Telephone: (415) 512-4000 4 Facsimile: (415) 512-4077 5 JOHN B. MAJOR (SBN 306416) 6 ANNE K. CONLEY (SBN 307952) 7 MUNGER, TOLLES & OLSON LLP 350 South Grand Avenue, Fiftieth Floor 8 Los Angeles, California 90071-3426 Telephone: (213) 683-9100 9 Facsimile: (213) 687-3702 10 Attorneys for Defendant SNAP INC. 11 12 UNITED STATES DISTRICT COURT 13 CENTRAL DISTRICT OF CALIFORNIA 14 15 CARLY LEMMON AND MICHAEL MORBY, as surviving parents of Hunter 16 Morby (deceased); MICHAEL MORBY, as administrator of the estate of Hunter 17 Morby (deceased); SAMANTHA AND MARLO BROWN, as surviving parents 18 of Landen Brown (deceased), STIPULATED PROTECTIVE ORDER Plaintiffs, 19 20 Case No. 2:19-cv-04504-MWF-KS v. 21 SNAP INC. (doing business in California as Snapchat, Inc.), 22 Defendant. 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER 1 1. A. PURPOSES AND LIMITATIONS 2 Defendant contends that Discovery in this action is likely to involve 3 production of confidential, proprietary, or private information for which special 4 protection from public disclosure and from use for any purpose other than 5 prosecuting this litigation may be warranted. The Plaintiffs do not agree with the 6 scope of the Defendant’s concern. However, the Defendant has declined to produce 7 any documents without a protective order. Accordingly, the parties hereby stipulate 8 to and petition the Court to enter the following Stipulated Protective Order. The 9 parties acknowledge that this Order does not confer blanket protections on all 10 disclosures or responses to discovery and that the protection it affords from public 11 disclosure and use extends only to the limited information or items that are entitled 12 to confidential treatment under the applicable legal principles. The parties further 13 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective 14 Order does not entitle them to file confidential information under seal; Civil Local 15 Rule 79-5 sets forth the procedures that must be followed and the standards that will 16 be applied when a party seeks permission from the court to file material under seal. 17 B. GOOD CAUSE STATEMENT 18 This action involves some documents that constitute trade secrets as reflected 19 in the Uniform Trade Secrets Act, as well as commercial, financial, technical and/or 20 proprietary information for which special protection from public disclosure and 21 from use for any purpose other than prosecution of this action may be warranted. 22 For example, the Plaintiffs consent to Defendant redacting the premium it paid for 23 any and all insurance policies that are providing liability coverage applicable to this 24 case. Potentially confidential and proprietary materials and information may consist 25 of, among other things, documents that reflect proprietary computer coding, or other 26 confidential business practices, research, development, or commercial information 27 which may be privileged or otherwise protected from disclosure under state or 28 federal statutes, court rules, case decisions, or common law. Accordingly, to -2- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 expedite the flow of information, to facilitate the prompt resolution of disputes over 2 confidentiality of discovery materials, to adequately protect information the 3 Defendant contends are entitled to be kept confidential, to ensure that the parties are 4 permitted reasonable necessary uses of such material in preparation for and in the 5 conduct of trial, to address their handling at the end of the litigation, and serve the 6 ends of justice, a protective order for such information is justified in this matter. It 7 is the intent of the parties that information will not be designated as confidential for 8 tactical reasons and that nothing be so designated without a good faith belief that it 9 has been maintained in a confidential, non-public manner, and there is good cause 10 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, Lemmon v. Snap Inc., Case No. 13 2:19-cv-04504-MWF-KS (C.D. Cal.). 14 2.2 Challenging Party: a Party or Non-Party that challenges the designation 15 of information or items under this Order. 16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 17 how it is generated, stored or maintained) or tangible things that qualify for protection 18 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 19 Cause Statement. 20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 21 support staff). 22 2.5 Designating Party: a Party or Non-Party that designates information or 23 items that it produces in disclosures or in responses to discovery as 24 “CONFIDENTIAL.” 25 2.6 Disclosure or Discovery Material: all items or information, regardless of 26 the medium or manner in which it is generated, stored, or maintained (including, 27 among other things, testimony, transcripts, and tangible things), that are produced or 28 generated in disclosures or responses to discovery in this matter. -3- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 2.7 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. 4 2.8 House Counsel: attorneys who are employees of a party to this Action 5 and support staff. House Counsel does not include Outside Counsel of Record or any 6 other outside counsel. 7 2.9 Non-Party: any natural person, partnership, corporation, association, or 8 other legal entity not named as a Party to this action. 9 2.10 Outside Counsel of Record: attorneys who are not employees of a party 10 to this Action but are retained to represent or advise a party to this Action and have 11 appeared in this Action on behalf of that party or are affiliated with a law firm which 12 has appeared on behalf of that party, and includes support staff. 13 2.11 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 2.13 Professional Vendors: persons or entities that provide litigation support 19 services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) 21 and their employees and subcontractors. 22 2.14 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 25 from a Producing Party. 26 3. SCOPE 27 The protections conferred by this Stipulation and Order cover not only 28 Protected Material (as defined above), but also (1) any information copied or -4- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 extracted from Protected Material; (2) all copies, excerpts, summaries, or 2 compilations of Protected Material; and (3) any testimony, conversations, or 3 presentations by Parties or their Counsel that might reveal Protected Material. 4 Any use of Protected Material at trial shall be governed by the orders of the 5 trial judge. This Order does not govern the use of Protected Material at trial. 6 4. DURATION 7 Even after final disposition of this litigation, the confidentiality obligations 8 imposed by this Order shall remain in effect until a Designating Party agrees 9 otherwise in writing or a court order otherwise directs. Final disposition shall be 10 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 11 or without prejudice; and (2) final judgment herein after the completion and 12 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 13 including the time limits for filing any motions or applications for extension of time 14 pursuant to applicable law. 15 5. DESIGNATING PROTECTED MATERIAL 16 5.1 Exercise of Restraint and Care in Designating Material for Protection. 17 Each Party or Non-Party that designates information or items for protection under this 18 Order must take care to limit any such designation to specific material that qualifies 19 under the appropriate standards. The Designating Party must designate for protection 20 only those parts of material, documents, items, or oral or written communications that 21 qualify so that other portions of the material, documents, items, or communications 22 for which protection is not warranted are not swept unjustifiably within the ambit of 23 this Order. 24 Mass, indiscriminate, or routinized designations are prohibited. Designations 25 that are shown to be clearly unjustified or that have been made for an improper 26 purpose (e.g., to unnecessarily encumber the case development process or to impose 27 unnecessary expenses and burdens on other parties) may expose the Designating 28 Party to sanctions. -5- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 If it comes to a Designating Party’s attention that information or items that it 2 designated for protection do not qualify for protection, that Designating Party must 3 promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2 Manner and Timing of Designations. Except as otherwise provided in 5 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 7 under this Order must be clearly so designated before the material is disclosed or 8 produced. 9 10 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 11 documents, but excluding transcripts of depositions or other pretrial or trial 12 proceedings), that the Producing Party affix at a minimum, the legend 13 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 14 contains protected material. If only a portion or portions of the material on a page 15 qualifies for protection, the Producing Party also must clearly identify the protected 16 portion(s) (e.g., by making appropriate markings in the margins). 17 A Party or Non-Party that makes original documents available for inspection 18 need not designate them for protection until after the inspecting Party has indicated 19 which documents it would like copied and produced. During the inspection and 20 before the designation, all of the material made available for inspection shall be 21 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 22 documents it wants copied and produced, the Producing Party must determine which 23 documents, or portions thereof, qualify for protection under this Order. Then, 24 before producing the specified documents, the Producing Party must affix the 25 CONFIDENTIAL legend” to each page that contains Protected Material. If only a 26 portion or portions of the material on a page qualifies for protection, the Producing 27 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 28 markings in the margins). -6- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 (b) for testimony given in depositions that the Designating Party identify the 2 Disclosure or Discovery Material on the record, before the close of the deposition all 3 protected testimony. 4 (c) for information produced in some form other than documentary and for 5 any other tangible items, that the Producing Party affix in a prominent place on the 6 exterior of the container or containers in which the information is stored the legend 7 “CONFIDENTIAL.” If only a portion or portions of the information warrants 8 protection, the Producing Party, to the extent practicable, shall identify the protected 9 portion(s). 10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 failure to designate qualified information or items does not, standing alone, waive the 12 Designating Party’s right to secure protection under this Order for such material. 13 Upon timely correction of a designation, the Receiving Party must make reasonable 14 efforts to assure that the material is treated in accordance with the provisions of this 15 Order. 16 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 18 designation of confidentiality at any time that is consistent with the Court’s 19 Scheduling Order. 20 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 21 resolution process under Local Rule 37.1 et seq. 22 6.3 The burden of persuasion in any such challenge proceeding shall be on 23 the Designating Party. Frivolous challenges, and those made for an improper purpose 24 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 25 expose the Challenging Party to sanctions. Unless the Designating Party has waived 26 or withdrawn the confidentiality designation, all parties shall continue to afford the 27 material in question the level of protection to which it is entitled under the Producing 28 Party’s designation until the Court rules on the challenge. -7- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection only with this 4 Action or claims presented in the case Maynard v. McGee et al., Case No. 16-SV-89 5 (Ga. State Ct.) (the “Maynard Litigation”), for prosecuting, defending, or attempting 6 to settle this Action or the Maynard Litigation; provided, however, that Protected 7 Material may only be used in connection with the Maynard Litigation if (i) all parties 8 to the Maynard Litigation have agreed to, and the trial court in the Maynard Litigation 9 has entered, a protective order providing protections equivalent to those contained in 10 this Order; and (ii) Snap has not objected to the use of the specific Protected Material 11 in the Maynard Litigation by, for example, designating particular Protected Material 12 as irrelevant to the Maynard Litigation or subject to third-party privacy concerns that 13 would preclude its use in the Maynard Litigation (subject to Plaintiffs’ ability to 14 challenge such a designation in the Maynard Litigation). Protected Material may be 15 disclosed only to the categories of persons and under the conditions described in this 16 Order. When the Action has been terminated, a Receiving Party must comply with 17 the provisions of section 13 below (FINAL DISPOSITION). 18 Protected Material must be stored and maintained by a Receiving Party at a 19 location and in a secure manner that ensures that access is limited to the persons 20 authorized under this Order. 21 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 22 otherwise ordered by the court or permitted in writing by the Designating Party, a 23 Receiving Party may disclose any information or item designated CONFIDENTIAL” 24 only to: 25 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 26 as employees of said Outside Counsel of Record to whom it is reasonably necessary 27 to disclose the information for this Action; 28 -8- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 (b) the officers, directors, and employees (including House Counsel) of the 2 Receiving Party to whom disclosure is reasonably necessary for this Action; 3 (c) Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (d) the court and its personnel; 7 (e) court reporters and their staff; 8 (f) professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have 10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (g) the author or recipient of a document containing the information or a 12 custodian or other person who otherwise possessed or knew the information; 13 (h) during their depositions, witnesses, and attorneys for witnesses, in the 14 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 15 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 16 not be permitted to keep any confidential information unless they sign the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 18 agreed by the Designating Party or ordered by the court. Pages of transcribed 19 deposition testimony or exhibits to depositions that reveal Protected Material may be 20 separately bound by the court reporter and may not be disclosed to anyone except as 21 permitted under this Stipulated Protective Order; and 22 (i) any mediator or settlement officer, and their supporting personnel, 23 mutually agreed upon by any of the parties engaged in settlement discussions. 24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 25 PRODUCED IN OTHER LITIGATION 26 If a Party is served with a subpoena or a court order issued in other litigation 27 that compels disclosure of any information or items designated in this Action as 28 “CONFIDENTIAL,” that Party must: -9- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 (a) promptly notify in writing the Designating Party. Such notification shall 2 include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or order to 4 issue in the other litigation that some or all of the material covered by the subpoena 5 or order is subject to this Protective Order. Such notification shall include copy of 6 this Stipulated Protective Order; and 7 (c) cooperate with respect to all reasonable procedures sought to be pursued 8 by the Designating Party whose Protected Material may be affected. In the event that 9 Defendant requests Plaintiff’s counsel to do any work associated with resisting or 10 responding to the subpoena or any motions that may follow, the Defendant shall 11 compensate Plaintiff’s counsel for its time without the creation of any attorney-client 12 relationship between the Plaintiff’s counsel and the Defendant. 13 If the Designating Party timely seeks a protective order, the Party served with 14 the subpoena or court order shall not produce any information designated in this 15 action as “CONFIDENTIAL” before a determination by the court from which the 16 subpoena or order issued, unless the Party has obtained the Designating Party’s 17 permission. The Designating Party shall bear the burden and expense of seeking 18 protection in that court of its confidential material and nothing in these provisions 19 should be construed as authorizing or encouraging a Receiving Party in this Action 20 to disobey a lawful directive from another court. 21 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 22 PRODUCED IN THIS LITIGATION 23 (a) The terms of this Order are applicable to information produced by a Non- 24 Party in this Action and designated as “CONFIDENTIAL.” Such information 25 produced by Non-Parties in connection with this litigation is protected by the 26 remedies and relief provided by this Order. Nothing in these provisions should be 27 construed as prohibiting a Non-Party from seeking additional protections. 28 -10- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 (b) In the event that a Party is required, by a valid discovery request, to 2 produce a Non-Party’s confidential information in its possession, and the Party is 3 subject to an agreement with the Non-Party not to produce the Non-Party’s 4 confidential information, then the Party shall: 5 (1) promptly notify in writing the Requesting Party and the Non-Party 6 that some or all of the information requested is subject to a confidentiality agreement 7 with a Non-Party; 8 (2) promptly provide the Non-Party with a copy of the Stipulated 9 Protective Order in this Action, the relevant discovery request(s), and a reasonably 10 specific description of the information requested; and 11 (3) make the information requested available for inspection by the 12 Non-Party, if requested. 13 (c) If the Non-Party fails to seek a protective order from this court within 14 14 days of receiving the notice and accompanying information, the Receiving Party may 15 produce the Non-Party’s confidential information responsive to the discovery request. 16 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 17 any information in its possession or control that is subject to the confidentiality 18 agreement with the Non-Party before a determination by the court. Absent a court 19 order to the contrary, the Non-Party shall bear the burden and expense of seeking 20 protection in this court of its Protected Material. 21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 23 Protected Material to any person or in any circumstance not authorized under this 24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 25 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 26 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 27 persons to whom unauthorized disclosures were made of all the terms of this Order, 28 -11- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 and (d) request such person or persons to execute the “Acknowledgment and 2 Agreement to Be Bound” that is attached hereto as Exhibit A. 3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 4 PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain 6 inadvertently produced material is subject to a claim of privilege or other protection, 7 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 8 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 9 procedure may be established in an e-discovery order that provides for production 10 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 11 (e), insofar as the parties reach an agreement on the effect of disclosure of a 12 communication or information covered by the attorney-client privilege or work 13 product protection, the parties may incorporate their agreement in the stipulated 14 protective order submitted to the court. 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 17 person to seek its modification by the Court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this 19 Protective Order no Party waives any right it otherwise would have to object to 20 disclosing or producing any information or item on any ground not addressed in this 21 Stipulated Protective Order. Similarly, no Party waives any right to object on any 22 ground to use in evidence of any of the material covered by this Protective Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any 24 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 25 only be filed under seal pursuant to a court order authorizing the sealing of the specific 26 Protected Material at issue. If a Party's request to file Protected Material under seal 27 is denied by the court, then the Receiving Party may file the information in the public 28 record unless otherwise instructed by the court. -12- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in 5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving 8 Party must submit a written certification to the Producing Party (and, if not the same 9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 10 (by category, where appropriate) all the Protected Material that was returned or 11 destroyed and (2) affirms that the Receiving Party has not retained any copies, 12 abstracts, compilations, summaries or any other format reproducing or capturing any 13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 16 reports, attorney work product, and consultant and expert work product, even if such 17 materials contain Protected Material. Any such archival copies that contain or 18 constitute Protected Material remain subject to this Protective Order as set forth in 19 Section 4 (DURATION). 20 14. VIOLATIONS 21 Any violation of this Order may be punished by any and all appropriate 22 measures including, without limitation, contempt proceedings and/or monetary 23 sanctions. 24 25 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 26 27 Dated: July 29, 2022 28 -13- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 /s/ D. Dwayne Adams 2 Thomas M. Dempsey (Cal. Bar No. 43311) 3 THE LAW OFFICES OF THOMAS M. DEMPSEY 4 433 N Camden Dr, Ste 370 Beverly Hills, CA 90210 5 Tel: 310-385-9600 Fax: 310-273-7679 6 Naveen Ramachandrappa (Ga, Bar No. 422036) 7 pro hac admitted 8 BONDURANT, MIXSON & ELMORE, LLP 1201 W Peachtree St NW, Ste 3900 9 Atlanta, GA 30309 Tel: 404-881-4100 10 Fax: 404-881-4111 11 Michael L. Neff (Ga. Bar No. 537180) pro hac admitted 12 D. Dwayne Adams (Ga. Bar. No. 140406) 13 pro hac admitted 14 LAW OFFICE OF MICHAEL LAWSON NEFF PC 3455 Peachtree Rd NE, Ste 509 15 Atlanta, GA 30326 Tel: 404-531-9700 16 Fax: 404-531-9727 17 Attorneys for Plaintiffs 18 /s/ John B. Major 19 JONATHAN H. BLAVIN (State Bar No. 230269) 20 MUNGER, TOLLES & OLSON LLP 560 Mission Street, Twenty-Seventh Floor 21 San Francisco, California 94105-2907 Telephone: (415) 512-4000 22 Facsimile: (415) 512-4077 23 JOHN B. MAJOR (State Bar No. 306416) 24 ANNE K. CONLEY (State Bar No. 307952) 25 MUNGER, TOLLES & OLSON LLP 350 South Grand Avenue, Fiftieth Floor 26 Los Angeles, California 90071-3426 Telephone: (213) 683-9100 27 Facsimile: (213) 687-3702 28 Attorneys for Defendant SNAP INC. -14- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 FILER’S ATTESTATION 2 Pursuant to L.R. 5-4.3.4(a)(2), I, John B. Major, certify that that all other 3 signatories listed, and on whose behalf the filing is submitted, concur in this filing’s 4 content and have authorized this filing. 5 6 7 By: /s/ John B. Major JOHN B. MAJOR 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -15- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 I, _____________________________ [print or type full name], of _______________________________________ [print or type full address], declare under penalty of perjury that I have read in its entirety and understand the Stipulated Protective Order that was issued by the United States District Court for the Central District of California on [date] in the case of Lemmon v. Snap Inc., Case No. 2:19cv-04504-MWF-KS (C.D. Cal.). I agree to comply with and to be bound by all the terms of this Stipulated Protective Order and I understand and acknowledge that failure to so comply could expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner any information or item that is subject to this Stipulated Protective Order to any person or entity except in strict compliance with the provisions of this Order. I further agree to submit to the jurisdiction of the United States District Court for the Central District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such enforcement proceedings occur after termination of this action. I hereby appoint __________________________ [print or type full name] of _______________________________________ [print or type full address and telephone number] as my California agent for service of process in connection with this action or any proceedings related to enforcement of this Stipulated Protective Order. Date: ______________________________________ 24 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 28 Signature: __________________________________ -17- STIPULATED PROTECTIVE ORDER Case No. 2:19-cv-04504-MWF-KS

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