Julian Vargas et al v. Quest Diagnostics Clinical Laboratories, Inc. et al

Filing 60

PROTECTIVE ORDER by Magistrate Judge Michael R. Wilner. re Stipulation for Protective Order 59 (vm)

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1 2 3 4 5 6 7 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. DAVID RAIZMAN, CA Bar No. 129407 david.raizman@ogletree.com AMBER L. ROLLER, CA Bar No. 273354 amber.roller@ogletree.com J. NICHOLAS MARFORI, CA Bar No. 311765 nicholas.marfori@ogletree.com 400 South Hope Street, Suite 1200 Los Angeles, California 90071 Telephone: 213-239-9800 Facsimile: 213-239-9045 Attorneys for Defendants QUEST DIAGNOSTICS CLINICAL LABORATORIES, INC.; QUEST 9 DIAGNOSTICS HOLDINGS, INC. and QUEST DIAGNOSTICS INCORPORATED 8 10 11 Counsel For Plaintiffs Listed on Next Page 12 UNITED STATES DISTRICT COURT 13 CENTRAL DISTRICT OF CALIFORNIA 14 15 JULIAN VARGAS, ANNE WEST and AMERICAN COUNCIL OF THE 16 BLIND, individually on behalf of themselves and all others similarly 17 situated, 18 19 Plaintiffs, QUEST DIAGNOSTICS CLINICAL 21 LABORATORIES, INC., QUEST DIAGNOSTICS HOLDINGS, INC., 22 QUEST DIAGNOSTICS INCORPORATED; and DOES 1-10, 23 inclusive, 24 STIPULATED PROTECTIVE ORDER (MRW VERSION 4/19) Check if submitted without material modifications to MRW form v. 20 Case No. 2:19-cv-08108 DMG (MRWx) Complaint Filed: September 18, 2019 Trial Date: October 5, 2021 District Judge: Hon. Dolly M. Gee Courtroom 8C, First St. Magistrate Judge: Hon. Michael R. Wilner Courtroom 550, Roybal Defendants. 25 26 27 28 Stipulated Protective Case No. 2:19-cv-08108 DMG (MRWx) STIPULATED PROTECTIVE ORDER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Jonathan D. Miller (Bar No. 220848) jonathan@nshmlaw.com Alison M. Bernal (Bar No. 264629) alison@nshmlaw.com NYE, STIRLING, HALE & MILLER, LLP 33 West Mission Street, Suite 201 Santa Barbara, CA 93101 Telephone: (805) 963-2345 Facsimile: (805) 284-9590 Benjamin J. Sweet (admission pro hac vice) ben@nshmlaw.com NYE, STIRLING, HALE & MILLER, LLP 1145 Bower Hill Road, Suite 104 Pittsburgh, PA 15243 Telephone: (412) 857-5350 Matthew K. Handley (admitted pro hac vice) mhandley@hfajustice.com HANDLEY FARAH & ANDERSON PLLC 777 6th St. NW Washington, DC 20001 Telephone: (202) 559-2411 18 Attorneys for Plaintiffs JULIAN VARGAS, ANNE WEST, and 20 AMERICAN COUNCIL OF THE BLIND 19 21 22 23 24 25 26 27 28 Stipulated Protective Case No. 2:19-cv-08108 DMG (MRWx) STIPULATED PROTECTIVE ORDER Plaintiffs Julian Vargas, Anne West, and American Council of the Blind 1 2 3 Inc., Quest Diagnostics Holdings, Inc., and Quest Diagnostics Incorporated 4 5 hereby stipulate and agree as follows: 6 1. INTRODUCTION 7 1.1. 8 Discovery in this action is likely to involve production of confidential, 9 PURPOSES AND LIMITATIONS proprietary, or private information for which special protection from public 10 disclosure and from use for any purpose other than prosecuting this litigation may be 11 warranted. Accordingly, the parties hereby stipulate to and petition the Court to 12 enter the following Stipulated Protective Order. The parties acknowledge that this 13 Order does not confer blanket protections on all disclosures or responses to 14 discovery and that the protection it affords from public disclosure and use extends 15 only to the limited information or items that are entitled to confidential treatment 16 under the applicable legal principles. The parties further acknowledge, as set forth in 17 Section 12.3, below, that this Stipulated Protective Order does not entitle them to file 18 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures 19 that must be followed and the standards that will be applied when a party seeks 20 permission from the court to file material under seal. 21 1.2. GOOD CAUSE STATEMENT 22 Defendants provide diagnostic testing information services. Quest patient services to 23 24 25 26 patients, including persons with disabilities. Plaintiffs brought this putative class inaccessible to patients with visual impairments in violation of the American with 27 28 Stipulated Protective Disabled Persons Act. Plaintiffs seek certification of a nationwide class of Case No. 2:19-cv-08108 DMG (MRWx) 1 STIPULATED PROTECTIVE ORDER 1 individuals with visual impairments who visited a PSC in the United States, and a 2 California sub-class of those visiting PSCs in California, and who were allegedly 3 denied full and equal enjoyment of the goods, services, facilities, privileges, 4 advantages, or accommodations because of the Kiosks. 5 Accordingly, this action is likely to involve trade secrets, customer/patient lists 6 and pricing information and other valuable research, development, commercial, 7 financial, technical and/or proprietary information for which special protection from 8 public disclosure and from use for any purpose other than prosecution of this action 9 is warranted. Such confidential and proprietary materials and information consist of, 10 among other things, confidential business or financial information, information 11 regarding patients, information regarding confidential business practices, or other 12 confidential research, development, or commercial information (including 13 information implicating privacy rights of third parties), information otherwise 14 generally unavailable to the public, or which may be privileged or otherwise 15 protected from disclosure under state or federal statutes, court rules, case decisions, 16 or common law. For Plaintiffs, confidential information is likely to consist of 17 medical and financial information. 18 Accordingly, to expedite the flow of information, to facilitate the prompt 19 resolution of disputes over confidentiality of discovery materials, to adequately 20 protect information the parties are entitled to keep confidential, to ensure that the 21 parties are permitted reasonable necessary uses of such material in preparation for 22 and in the conduct of trial, to address their handling at the end of the litigation, and 23 serve the ends of justice, a protective order for such information is justified in this 24 matter. It is the intent of the parties that information will not be designated as 25 confidential for tactical reasons and that nothing be so designated without a good 26 faith belief that it has been maintained in a confidential, non-public manner, and 27 there is good cause why it should not be part of the public record of this case. 28 Stipulated Protective Case No. 2:19-cv-08108 DMG (MRWx) 2 STIPULATED PROTECTIVE ORDER 1 2 3 4 5 6 2. DEFINITIONS 2.1 Action: Julian Vargas, et al. v. Quest Diagnostics Clinical Laboratories, Inc., et al., U.S.D.C. Case No. 2:19-cv-08108-DMG-MRW 2.2 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.3 : information (regardless of 7 how it is generated, stored or maintained) or tangible things that qualify for 8 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 9 Good Cause Statement. 10 11 12 13 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 items that it produces in disclosures or in responses to discovery as 14 15 2.6 Disclosure or Discovery Material: all items or information, regardless 16 of the medium or manner in which it is generated, stored, or maintained (including, 17 among other things, testimony, transcripts, and tangible things), that are produced or 18 generated in disclosures or responses to discovery in this matter. 19 2.7 Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its counsel to serve as 21 an expert witness or as a consultant in this Action. 22 2.8 House Counsel: attorneys who are employees of a party to this Action. 23 House Counsel does not include Outside Counsel of Record or any other outside 24 counsel. 25 26 27 28 Stipulated Protective 2.9 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this Action but are retained to represent or advise a party to this Action and have Case No. 2:19-cv-08108 DMG (MRWx) 3 STIPULATED PROTECTIVE ORDER 1 appeared in this Action on behalf of that party or are affiliated with a law firm which 2 has appeared on behalf of that party, and includes support staff. 2.11 Party: any party to this Action, including all of its officers, directors, 3 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 6 7 Discovery Material in this Action. 2.13 Professional Vendors: persons or entities that provide litigation support 8 9 services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) 11 and their employees and subcontractors. 2.14 Protected Material: any Disclosure or Discovery Material that is 12 13 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 14 15 from a Producing Party. 16 17 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 Protected Material (as defined above), but also (1) any information copied or 20 extracted from Protected Material; (2) all copies, excerpts, summaries, or 21 compilations of Protected Material; and (3) any testimony, conversations, or 22 presentations by Parties or their Counsel that might reveal Protected Material. Any use of Protected Material at trial will be governed by the orders of the 23 24 trial judge. This Order does not govern the use of Protected Material at trial. 25 26 27 28 Stipulated Protective 4. DURATION Once a case proceeds to trial, all of the information that was designated as confidential or maintained pursuant to this protective order becomes public and will Case No. 2:19-cv-08108 DMG (MRWx) 4 STIPULATED PROTECTIVE ORDER 1 be presumptively available to all members of the public, including the press, unless 2 compelling reasons supported by specific factual findings to proceed otherwise are 3 made to the trial judge in advance of the trial. See Kamakana v. City and County of 4 Honolulu, 447 F.3d 1172, 1180- 5 6 standard when merits-related documents are part of court record). Accordingly, the 7 terms of this protective order do not extend beyond the commencement of the trial. 8 9 10 5. DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 11 Each Party or Non-Party that designates information or items for protection under 12 this Order must take care to limit any such designation to specific material that 13 qualifies under the appropriate standards. The Designating Party must designate for 14 protection only those parts of material, documents, items, or oral or written 15 communications that qualify so that other portions of the material, documents, items, 16 or communications for which protection is not warranted are not swept unjustifiably 17 within the ambit of this Order. 18 Mass, indiscriminate, or routinized designations are prohibited. Designations 19 that are shown to be clearly unjustified or that have been made for an improper 20 purpose (e.g., to unnecessarily encumber the case development process or to impose 21 unnecessary expenses and burdens on other parties) may expose the Designating 22 Party to sanctions. 23 24 designated for protection do not qualify for protection, that Designating Party must 25 promptly notify all other Parties that it is withdrawing the inapplicable designation. 26 5.2 Manner and Timing of Designations. Except as otherwise provided in 27 28 Stipulated Protective this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for protection Case No. 2:19-cv-08108 DMG (MRWx) 5 STIPULATED PROTECTIVE ORDER 1 under this Order must be clearly so designated before the material is disclosed or 2 produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or electronic 5 documents, but excluding transcripts of depositions or other pretrial or trial 6 proceedings), that the Producing Party affix at a minimum, the legend 7 8 contains protected material. If only a portion or portions of the material on a page 9 qualifies for protection, the Producing Party also must clearly identify the protected 10 portion(s) (e.g., by making appropriate markings in the margins). A Party or Non-Party that makes original documents available for 11 12 inspection need not designate them for protection until after the inspecting Party has 13 indicated which documents it would like copied and produced. During the 14 inspection and before the designation, all of the material made available for 15 16 identified the documents it wants copied and produced, the Producing Party must 17 determine which documents, or portions thereof, qualify for protection under this 18 Order. Then, before producing the specified documents, the Producing Party must 19 20 If only a portion or portions of the material on a page qualifies for protection, the 21 Producing Party also must clearly identify the protected portion(s) (e.g., by making 22 appropriate markings in the margins). 23 (b) for testimony given in depositions that the Designating Party identify 24 the Disclosure or Discovery Material on the record, before the close of the deposition 25 all protected testimony. 26 (c) for information produced in some form other than documentary and for 27 28 Stipulated Protective any other tangible items, that the Producing Party affix in a prominent place on the exterior of the container or containers in which the information is stored the legend Case No. 2:19-cv-08108 DMG (MRWx) 6 STIPULATED PROTECTIVE ORDER 1 2 protection, the Producing Party, to the extent practicable, will identify the protected 3 portion(s). 5.3 4 5 Inadvertent Failures to Designate. An inadvertent failure to designate qualified information or items (if promptly corrected upon discovery of such 6 7 secure protection under this Order for such material. Upon timely correction of a 8 designation, the Receiving Party must make reasonable efforts to assure that the 9 material is treated in accordance with the provisions of this Order. 10 11 12 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 13 14 15 Scheduling Order. 6.2 Meet and Confer. The Challenging Party will initiate the dispute 16 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 17 et seq. Any challenge submitted to the Court shall be made by a joint stipulation 18 pursuant to Local Rule 37-2. 19 6.3 The burden of persuasion in any such challenge proceeding will be on 20 the Designating Party. Frivolous challenges, and those made for an improper 21 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 22 parties) may expose the Challenging Party to sanctions. Unless the Designating 23 Party has waived or withdrawn the confidentiality designation, all parties will 24 continue to afford the material in question the level of protection to which it is 25 26 challenge. 27 28 Stipulated Protective Case No. 2:19-cv-08108 DMG (MRWx) 7 STIPULATED PROTECTIVE ORDER 1 2 7. ACCESS TO AND USE OF PROTECTED MATERIAL 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 with this 4 Action only for prosecuting, defending, or attempting to settle this Action. Such 5 Protected Material may be disclosed only to the categories of persons and under the 6 conditions described in this Order. When the Action has been terminated, a 7 Receiving Party must comply with the provisions of section 13 below (FINAL 8 DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a 10 location and in a secure manner that ensures that access is limited to the persons 11 authorized under this Order. 12 7.2 . Unless 13 otherwise ordered by the court or permitted in writing by the Designating Party, a 14 Receiving Party may disclose any information or item designated 15 16 (a) 17 as employees of said Outside Counsel of Record to whom it is reasonably necessary 18 to disclose the information for this Action; 19 20 21 22 (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 disclosure is reasonably necessary for this Action and who have signed the 23 24 (d) the Court and its personnel; 25 (e) court reporters and their staff; 26 (f) professional jury or trial consultants, mock jurors, and Professional 27 Vendors to whom disclosure is reasonably necessary for this Action and who have 28 Stipulated Protective Case No. 2:19-cv-08108 DMG (MRWx) 8 STIPULATED PROTECTIVE ORDER (g) 1 2 the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; (h) 3 during their depositions, witnesses, and attorneys for witnesses, in the 4 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 5 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 6 not be permitted to keep any confidential information unless they sign the 7 8 agreed by the Designating Party or ordered by the court. Pages of transcribed 9 deposition testimony or exhibits to depositions that reveal Protected Material may be 10 separately bound by the court reporter and may not be disclosed to anyone except as 11 permitted under this Stipulated Protective Order; and (i) 12 13 any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 14 15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 16 PRODUCED IN OTHER LITIGATION 17 If a Party is served with a subpoena or a court order issued in other litigation 18 that compels disclosure of any information or items designated in this Action as 19 20 21 22 (a) promptly notify in writing the Designating Party. Such notification will include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order 23 to issue in the other litigation that some or all of the material covered by the 24 subpoena or order is subject to this Protective Order. Such notification will include a 25 copy of this Stipulated Protective Order; and 26 27 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 28 Stipulated Protective Case No. 2:19-cv-08108 DMG (MRWx) 9 STIPULATED PROTECTIVE ORDER If the Designating Party timely seeks a protective order, the Party served with 1 2 the subpoena or court order will not produce any information designated in this 3 4 subpoena or order issued, unless 5 permission. The Designating Party will bear the burden and expense of seeking 6 protection in that court of its confidential material and nothing in these provisions 7 should be construed as authorizing or encouraging a Receiving Party in this Action 8 to disobey a lawful directive from another court. 9 10 9. A NON- TED MATERIAL SOUGHT TO BE 11 PRODUCED IN THIS LITIGATION 12 (a) The terms of this Order are applicable to information produced by a 13 Non-Party in this A 14 produced by Non-Parties in connection with this litigation is protected by the 15 remedies and relief provided by this Order. Nothing in these provisions should be 16 construed as prohibiting a Non-Party from seeking additional protections. 17 (b) 18 produce a Non- 19 subject to an agreement with the Non-Party not to produce the Non- 20 confidential information, then the Party will: 21 In the event that a Party is required, by a valid discovery request, to (1) promptly notify in writing the Requesting Party and the Non- 22 Party that some or all of the information requested is subject to a confidentiality 23 agreement with a Non-Party; 24 (2) promptly provide the Non-Party with a copy of the Stipulated 25 Protective Order in this Action, the relevant discovery request(s), and a reasonably 26 specific description of the information requested; and 27 28 Stipulated Protective (3) make the information requested available for inspection by the Non-Party, if requested. Case No. 2:19-cv-08108 DMG (MRWx) 10 STIPULATED PROTECTIVE ORDER (c) 1 If the Non-Party fails to seek a protective order from this court within 2 14 days of receiving the notice and accompanying information, the Receiving Party 3 may produce the Non- 4 request. If the Non-Party timely seeks a protective order, the Receiving Party will 5 not produce any information in its possession or control that is subject to the 6 confidentiality agreement with the Non-Party before a determination by the court. 7 Absent a court order to the contrary, the Non-Party will bear the burden and expense 8 of seeking protection in this court of its Protected Material. o the discovery 9 10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 12 Protected Material to any person or in any circumstance not authorized under this 13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 14 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 15 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 16 persons to whom unauthorized disclosures were made of all the terms of this Order, dgment and 17 18 19 section 10 shall limit in any way the relief the Designating Party may seek or obtain 20 against the Receiving Party for any violation of this Order. 21 22 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 When a Producing Party gives notice to Receiving Parties that certain 25 26 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 27 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 28 Stipulated Protective inadvertently produced material is subject to a claim of privilege or other protection, may be established in an e-discovery order that provides for production without prior Case No. 2:19-cv-08108 DMG (MRWx) 11 STIPULATED PROTECTIVE ORDER 1 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 2 parties reach an agreement on the effect of disclosure of a communication or 3 information covered by the attorney-client privilege or work product protection, the 4 parties may incorporate their agreement in the stipulated protective order submitted 5 to the court. 6 7 12. 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 8 9 MISCELLANEOUS person to seek its modification by the Court in the future. 12.2 Right to Assert Other Objections. By stipulating to the entry of this 10 11 Protective Order no Party waives any right it otherwise would have to object to 12 disclosing or producing any information or item on any ground not addressed in this 13 Stipulated Protective Order. Similarly, no Party waives any right to object on any 14 ground to use in evidence of any of the material covered by this Protective Order. 12.3 Filing Protected Material. A Party that seeks to file under seal any 15 16 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 17 only be filed under seal pursuant to a court order authorizing the sealing of the 18 specific Protected Material at issue. If a Party's request to file Protected Material 19 under seal is denied by the court, then the Receiving Party may file the information 20 in the public record unless otherwise instructed by the court. 21 22 13. FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 4, within 60 23 24 25 all Protected Material to the Producing Party or destroy such material. As used in 26 this s 27 summaries, and any other format reproducing or capturing any of the Protected 28 Stipulated Protective days of a written request by the Designating Party, each Receiving Party must return Material. Whether the Protected Material is returned or destroyed, the Receiving Case No. 2:19-cv-08108 DMG (MRWx) 12 STIPULATED PROTECTIVE ORDER 1 Party must submit a written certification to the Producing Party (and, if not the same 2 person or entity, to the Designating Party) by the 60-day deadline that (1) identifies 3 (by category, where appropriate) all the Protected Material that was returned or 4 destroyed and (2) affirms that the Receiving Party has not retained any copies, 5 abstracts, compilations, summaries or any other format reproducing or capturing any 6 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 7 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 8 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 9 reports, attorney work product, and consultant and expert work product, even if such 10 materials contain Protected Material. Any such archival copies that contain or 11 constitute Protected Material remain subject to this Protective Order as set forth in 12 Section 4 (DURATION). 13 14 14. 15 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 16 authorities, or other appropriate action at the discretion of the Court. 17 Any willful violation of this Order may be punished by civil or criminal IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. Respectfully submitted, 18 19 DATED: November 16, 2020 NYE, STIRLING, HALE & MILLER, LLP 20 21 22 23 24 25 By: /s/ Alison M. Bernal Jonathan D. Miller Benjamin J. Sweet Alison M. Bernal Attorneys for Plaintiffs JULIAN VARGAS, ANNE WEST, AND AMERICAN COUNCIL OF THE BLIND 26 27 28 Stipulated Protective Case No. 2:19-cv-08108 DMG (MRWx) 13 STIPULATED PROTECTIVE ORDER 1 2 DATED: November 16, 2020 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 3 4 By: /s/ Amber L. Roller David Raizman Amber L. Roller J. Nicholas Marfori 5 6 Attorneys for Defendants QUEST DIAGNOSTICS CLINICAL LABORATORIES, INC.; QUEST DIAGNOSTICS HOLDINGS, INC. and QUEST DIAGNOSTICS INCORPORATED 7 8 9 10 11 12 13 Certification Pursuant to Local Rule 5-4.3.4(a)(2)(i) Pursuant to Local Rule 5-4.3.4(a)(2)(i), I, Amber L. Roller, do attest that all 14 signatories listed, and on whose behalf the filing is 15 content and have authorized the filing. 16 17 Dated: November 16, 2020 By: /s/ Amber L. Roller Amber L. Roller 18 19 20 21 22 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23 24 25 11/18/2020 DATED: ___________________ __________________________________ HON. MICHAEL R. WILNER United States Magistrate Judge 26 27 28 Stipulated Protective Case No. 2:19-cv-08108 DMG (MRWx) 14 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [full name], of ___________________ 5 _______________________ [full address], declare under penalty of perjury that I 6 have read in its entirety and understand the Stipulated Protective Order that was 7 issued by the United States District Court for the Central District of California on 8 [date] in the case of ___________ [insert case name and number]. I agree to 9 comply with and to be bound by all the terms of this Stipulated Protective Order and 10 I understand and acknowledge that failure to so comply could expose me to sanctions 11 and punishment in the nature of contempt. I solemnly promise that I will not disclose 12 in any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this 14 Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [full 19 name] of _____________________________________________ [full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________ 24 City and State where signed: ___________________________________________ 25 Printed name: _______________________________________________________ 26 Signature: __________________________________________________________ 27 28 Stipulated Protective EXHIBIT A Case No. 2:19-cv-08108 DMG (MRWx) 1 STIPULATED PROTECTIVE ORDER

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