Brian Thomassen v. Gebruder Weiss, Inc, et al

Filing 36

STIPULATED PROTECTIVE ORDER by Magistrate Judge Charles F. Eick re Stipulation for Protective Order. 35 (See document for details) (vmun)

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1 Erica H. Chen (SBN 312806) chen.erica@dorsey.com 2 Melonie S. Jordan (SBN 331602) jordan.melonie@dorsey.com 3 DORSEY & WHITNEY LLP 600 Anton Boulevard, Suite 2000 4 Costa Mesa, CA 92626-7655 Telephone: (714) 800-1400 5 Facsimile: (714) 800-1499 6 John T. Sullivan (Admitted Pro Hac Vice) sullivan.jack@dorsey.com 7 DORSEY & WHITNEY LLP 50 South Sixth Street, Suite 1500 8 Minneapolis, MN 55402-1498 Telephone: (612) 340-2600 9 Facsimile: (612) 340-2868 10 Attorneys for Defendant Gebrüder Weiss, Inc. 11 12 UNITED STATES DISTRICT COURT 13 CENTRAL DISTRICT OF CALIFORNIA—WESTERN DIVISION 14 15 BRIAN THOMASSEN, an individual, 16 Plaintiff, 17 18 19 20 21 vs. GEBRÜDER WEISS, INC. and Does 1 through 50, CASE NO: 2:20-cv-08308 AB (Ex) Assigned to: Hon. Andre Birotte, Jr. Courtroom 7B Referred to: Magistrate Judge Charles F. Eick Courtroom 750, 7th Fl. Defendants. STIPULATED PROTECTIVE ORDER 22 23 24 25 26 Complaint Filed: Action Removed: Trial Date: August 3, 2020 September 10, 2020 March 1, 2022 27 28 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, proprietary, 3 or private information for which special protection from public disclosure and from use 4 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the 5 parties hereby stipulate to and petition the Court to enter the following Stipulated 6 Protective Order. The parties acknowledge that this Stipulated Protective Order does not 7 confer blanket protections on all disclosures or responses to discovery and that the 8 protection it affords from public disclosure and use extends only to the limited information 9 or items that are entitled to confidential treatment under this Stipulated Protective Order. 10 The parties further acknowledge, as set forth in Section 13.3 below, that this Stipulated 11 Protective Order does not entitle them to file confidential information under seal; Local 12 Rule 79-5 sets forth the procedures that must be followed and the standards that will be 13 applied when a party seeks permission from the Court to file material under seal. 14 Discovery in this action is likely to involve production of confidential, proprietary, or 15 private information for which special protection from public disclosure and from use for 16 any purpose other than prosecuting this litigation may be warranted. 17 2. GOOD CAUSE STATEMENT 18 Defendant contends that discovery in this action may involve trade secrets, 19 customer and pricing lists and other valuable research, development, commercial, 20 financial, technical and/or proprietary information for which special protection from public 21 disclosure and from use for any purpose other than prosecution of this action is warranted, 22 especially because the parties are engaged in the same or similar businesses. Such 23 confidential and proprietary materials and information consist of, among other things, 24 confidential business or financial information, information regarding confidential business 25 practices and/or confidential and proprietary trade secrets (including customer and pricing 26 lists), or other confidential research, development, or commercial information (including 27 information implicating privacy rights of third parties), information otherwise generally 28 unavailable to the public, or which may be privileged or otherwise protected from 1 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 disclosure under state or federal statutes, court rules, case decisions, or common law. 2 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 3 disputes over confidentiality of discovery materials, to adequately protect information the 4 parties are entitled to keep confidential, to ensure that the parties are permitted reasonable 5 necessary uses of such material in preparation for and in the conduct of trial, to address 6 their handling at the end of the litigation, and to serve the ends of justice, a protective order 7 for such information is justified in this matter. It is the intent of the parties that information 8 will not be designated as confidential for tactical reasons and that nothing be so designated 9 without a good faith belief that it has been maintained in a confidential, non-public manner, 10 and there is good cause why it should not be part of the public record of this case. 11 3. DEFINITIONS 12 3.1. Action: This pending federal lawsuit. 13 3.2. Challenging Party: A Party or Nonparty that challenges the designation of 14 CONFIDENTIAL Information or Items under this Stipulated Protective 15 Order. 16 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of how it 17 is generated, stored or maintained) or tangible things that qualify for 18 protection under Federal Rule of Civil Procedure 26(c), and as specified 19 above in the Good Cause Statement. 20 3.4 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Information or Items: 21 “CONFIDENTIAL” information that is highly confidential or proprietary in 22 nature that qualified for protection under Federal Rule of Civil Procedure 23 26(c), as specified above in the Good Cause Statement. 24 3.5. support staff). 25 26 Counsel: Outside Counsel of Record and In-House Counsel (as well as their 3.6. Designating Party: A Party or Nonparty that designates information or items 27 that it produces in disclosures or in responses to discovery as 28 “CONFIDENTIAL.” 2 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 3.7. Disclosure or Discovery Material: All items or information, regardless of the 2 medium or manner in which it is generated, stored, or maintained (including, 3 among other things, testimony, transcripts, and tangible things), that is 4 produced or generated in disclosures or responses to discovery in this matter. 5 3.8. Expert: A person with specialized knowledge or experience in a matter 6 pertinent to the litigation who has been retained by a Party or its counsel to 7 serve as an expert witness or as a consultant in this Action. 8 9 10 11 12 3.9. In-House Counsel: Attorneys who are employees of a party to this Action. In-House Counsel does not include Outside Counsel of Record or any other outside counsel. 3.10. Nonparty: Any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 13 3.11. Outside Counsel of Record: Attorneys who are not employees of a party to 14 this Action but are retained to represent or advise a party to this Action and 15 have appeared in this Action on behalf of that party or are affiliated with a 16 law firm which has appeared on behalf of that party, and includes support 17 staff. 18 3.12. Party: Any party to this Action, including all of its officers, directors, 19 employees, consultants, retained experts, In-House Counsel, and Outside 20 Counsel of Record (and their support staffs). 21 22 3.13. Producing Party: A Party or Nonparty that produces Disclosure or Discovery Material in this Action. 23 3.14. Professional Vendors: Persons or entities that provide litigation support 24 services (e.g., photocopying, videotaping, translating, preparing exhibits or 25 demonstrations, and organizing, storing, or retrieving data in any form or 26 medium) and their employees and subcontractors. 27 3.15. Protected Material: Any Disclosure or Discovery Material that is designated 28 as “CONFIDENTIAL” or “CONFIDENTIAL—ATTORNEYS’ EYES 3 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) ONLY.” 1 2 3.16. Receiving Party: A Party that receives Disclosure or Discovery Material from a Producing Party. 3 4 4. SCOPE 5 The protections conferred by this Stipulated Protective Order cover not only 6 Protected Material, but also (1) any information copied or extracted from Protected 7 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and 8 (3) any testimony, conversations, or presentations by Parties or their Counsel that might 9 reveal Protected Material. 10 Any use of Protected Material at trial shall be governed by the orders of the trial 11 judge. This Stipulated Protective Order does not govern the use of Protected Material at 12 trial. 13 5. DURATION 14 Even after final disposition of this litigation, the confidentiality obligations imposed 15 by this Stipulated Protective Order shall remain in effect until a Designating Party agrees 16 otherwise in writing or a court order otherwise directs. Final disposition shall be deemed 17 to be the later of (1) dismissal of all claims and defenses in this Action, with or without 18 prejudice; and (2) final judgment herein after the completion and exhaustion of all appeals, 19 rehearings, remands, trials, or reviews of this Action, including the time limits for filing 20 any motions or applications for extension of time pursuant to applicable law. 21 6. DESIGNATING PROTECTED MATERIAL 22 6.1. 23 Each Party or Nonparty that designates information or items for protection under Exercise of Restraint and Care in Designating Material for Protection. 24 this Stipulated Protective Order must take care to limit any such designation to specific 25 material that qualifies under the appropriate standards. The Designating Party must 26 designate for protection only those parts of material, documents, items, or oral or written 27 communications that qualify so that other portions of the material, documents, items, or 28 communications for which protection is not warranted are not swept unjustifiably within 4 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 the ambit of this Stipulated Protective Order. 2 Mass, indiscriminate, or routinized designations are prohibited. Designations that 3 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 4 to unnecessarily encumber the case development process or to impose unnecessary 5 expenses and burdens on other parties) may expose the Designating Party to sanctions. 6 6.2. Manner and Timing of Designations. 7 Except as otherwise provided in this Stipulated Protective Order (see, e.g., Section 8 6.2(a)), or as otherwise stipulated or ordered, Disclosure or Discovery Material that 9 qualifies for protection under this Stipulated Protective Order must be clearly so 10 designated before the material is disclosed or produced. 11 Designation in conformity with this Stipulated Protective Order requires the 12 following: 13 (a) For information in documentary form (e.g., paper or electronic 14 documents, but excluding transcripts of depositions or other pretrial or 15 trial proceedings), that the Producing Party affix at a minimum, the 16 legend “CONFIDENTIAL” or “CONFIDENTIAL—ATTORNEYS’ 17 EYES ONLY” to each page that contains protected material. If only a 18 portion or portions of the material on a page qualifies for protection, 19 the Producing Party also must clearly identify the protected portion(s) 20 (e.g., by making appropriate markings in the margins). 21 A Party or Nonparty that makes original documents available for 22 inspection need not designate them for protection until after the 23 inspecting Party has indicated which documents it would like copied 24 and produced. During the inspection and before the designation, all of 25 the material made available for inspection shall be deemed 26 “CONFIDENTIAL or “CONFIDENTIAL—ATTORNEYS’ EYES 27 ONLY.” After the inspecting Party has identified the documents it 28 wants copied and produced, the Producing Party must determine which 5 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 documents, or portions thereof, qualify for protection under this 2 Stipulated Protective Order. Then, before producing the specified 3 documents, 4 “CONFIDENTIAL” or “CONFIDENTIAL—ATTORNEYS’ EYES 5 ONLY” to each page that contains Protected Material. If only a portion 6 or portions of the material on a page qualifies for protection, the 7 Producing Party also must clearly identify the protected portion(s) 8 (e.g., by making appropriate markings in the margins). (b) 9 the Producing Party must affix the legend For testimony given in depositions, that the Designating Party identify 10 the Disclosure or Discovery Material on the record, before the close of 11 the deposition, all protected testimony. (c) 12 For information produced in nondocumentary form, and for any other 13 tangible items, that the Producing Party affix in a prominent place on 14 the exterior of the container or containers in which the information is 15 stored the legend “CONFIDENTIAL” or “CONFIDENTIAL— 16 ATTORNEYS’ EYES ONLY”. If only a portion or portions of the 17 information warrants protection, the Producing Party, to the extent 18 practicable, shall identify the protected portion(s). 19 6.3. Inadvertent Failure to Designate. 20 If timely corrected, an inadvertent failure to designate qualified information or items 21 does not, standing alone, waive the Designating Party’s right to secure protection under 22 this Stipulated Protective Order for such material. “Timely corrected” shall mean that the 23 Designating Party notifies the receiving party(ies) within 30 days of the original Disclosure 24 or production of the Discovery Material of the Designating Party’s inadvertent failure to 25 designate the 26 contemporaneous Disclosure or production Discovery of the Materials Disclosure or as CONFIDENTIAL Discovery Materials and as 27 CONFIDENTIAL. Upon timely correction of a designation, the Receiving Party must 28 make reasonable efforts to assure that the material is treated in accordance with the 6 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 provisions of this Stipulated Protective Order. 2 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 3 7.1. 4 Any Party or Nonparty may challenge a designation of confidentiality at any time Timing of Challenges. 5 that is consistent with the Court’s Scheduling Order. 6 7.2. Meet and Confer. 7 The Challenging Party shall initiate the dispute resolution process, which shall 8 comply with Local Rule 37.1 et seq. 9 10 7.3. Burden of Persuasion. The burden of persuasion in any such challenge proceeding shall be on the 11 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 12 to harass or impose unnecessary expenses and burdens on other parties) may expose the 13 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 14 the confidentiality designation, all parties shall continue to afford the material in question 15 the level of protection to which it is entitled under the Producing Party’s designation until 16 the Court rules on the challenge. 17 8. ACCESS TO AND USE OF PROTECTED MATERIALS 18 8.1. 19 A Receiving Party may use Protected Material that is disclosed or produced by Basic Principles. 20 another Party or by a Nonparty in connection with this Action only for prosecuting, 21 defending, or attempting to settle this Action. Such Protected Material may be disclosed 22 only to the categories of persons and under the conditions described in this Stipulated 23 Protective Order. When the Action reaches a final disposition, a Receiving Party must 24 comply with the provisions of Section 14 below. 25 Protected Material must be stored and maintained by a Receiving Party at a location 26 and in a secure manner that ensures that access is limited to the persons authorized under 27 this Stipulated Protective Order. 28 8.2. Disclosure of “CONFIDENTIAL” or “CONFIDENTIAL—ATTORNEYS’ 7 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 2 EYES ONLY” Information or Items. Unless otherwise ordered by the Court or permitted in writing by the Designating 3 Party, a Receiving Party may disclose any information or item designated 4 “CONFIDENTIAL” or “CONFIDENTIAL—ATTORNEYS’ EYES ONLY” only to: 5 (a) The Receiving Party’s Outside Counsel of Record, as well as 6 employees of said Outside Counsel of Record to whom it is reasonably 7 necessary to disclose the information for this Action; 8 (b) of the Receiving Party to whom disclosure is reasonably necessary for 9 this Action; 10 11 The officers, directors, and employees (including In-House Counsel) (c) Experts of the Receiving Party to whom disclosure is reasonably 12 necessary for this Action and who have signed the “Acknowledgment 13 and Agreement to Be Bound” (Exhibit A); 14 (d) The Court and its personnel; 15 (e) Court reporters and their staff; 16 (f) Professional jury or trial consultants, mock jurors, and Professional 17 Vendors to whom disclosure is reasonably necessary or this Action and 18 who have signed the “Acknowledgment and Agreement to be Bound” 19 (Exhibit A); 20 (g) The author or recipient of a document containing the information or a 21 custodian or other person who otherwise possessed or knew the 22 information; 23 (h) During their depositions, witnesses, and attorneys for witnesses, in the 24 Action to whom disclosure is reasonably necessary provided: (i) the 25 deposing party requests that the witness sign the “Acknowledgment 26 and Agreement to Be Bound” (Exhibit A); and (ii) the witness will not 27 be permitted to keep any confidential information unless they sign the 28 “Acknowledgment and Agreement to Be Bound,” unless otherwise 8 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 agreed by the Designating Party or ordered by the Court. Pages of 2 transcribed deposition testimony or exhibits to depositions that reveal 3 Protected Material may be separately bound by the court reporter and 4 may not be disclosed to anyone except as permitted under this 5 Stipulated Protective Order; and (i) 6 Any mediator or settlement officer, and their supporting personnel, 7 mutually agreed upon by any of the parties engaged in settlement 8 discussions. 9 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 10 OTHER LITIGATION 11 If a Party is served with a subpoena or a court order issued in other litigation that 12 compels disclosure of any information or items designated in this Action as 13 “CONFIDENTIAL” or “CONFIDENTIAL—ATTORNEYS’ EYES ONLY,” that Party 14 must: 15 (a) include a copy of the subpoena or court order; 16 17 Promptly notify in writing the Designating Party. Such notification shall (b) Promptly notify in writing the party who caused the subpoena or order to issue 18 in the other litigation that some or all of the material covered by the subpoena 19 or order is subject to this Stipulated Protective Order. Such notification shall 20 include a copy of this Stipulated Protective Order; and 21 22 23 (c) Cooperate with respect to all reasonable procedures sought to be 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 24 subpoena or court order shall not produce any information designated in this action as 25 “CONFIDENTIAL” or “CONFIDENTIAL—ATTORNEYS’ EYES ONLY” before a 26 determination by the Court from which the subpoena or order issued, unless the Party has 27 obtained the Designating Party’s permission. The Designating Party shall bear the burden 28 and expense of seeking protection in that court of its confidential material and nothing in 9 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 these provisions should be construed as authorizing or encouraging a Receiving Party in 2 this Action to disobey a lawful directive from another court. 3 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 4 IN THIS LITIGATION 5 10.1. Application. 6 The terms of this Stipulated Protective Order are applicable to information produced 7 by a Nonparty in this Action and designated as “CONFIDENTIAL” or 8 “CONFIDENTIAL—ATTORNEYS’ EYES ONLY.” Such information produced by 9 Nonparties in connection with this litigation is protected by the remedies and relief 10 provided by this Stipulated Protective Order. Nothing in these provisions should be 11 construed as prohibiting a Nonparty from seeking additional protections. 12 10.2. Notification. 13 In the event that a Party is required, by a valid discovery request, to produce a 14 Nonparty’s confidential information in its possession, and the Party is subject to an 15 agreement with the Nonparty not to produce the Nonparty’s confidential information, then 16 the Party shall: 17 (a) Promptly notify in writing the Requesting Party and the Nonparty that 18 some or all of the information requested is subject to a confidentiality 19 agreement with a Nonparty; 20 (b) Promptly provide the Nonparty with a copy of the Stipulated Protective 21 Order in this Action, the relevant discovery request(s), and a 22 reasonably specific description of the information requested; and 23 24 (c) Make the information requested available for inspection by the Nonparty, if requested. 25 10.3. Conditions of Production. 26 If the Nonparty fails to seek a protective order from this Court within fourteen (14) 27 days after receiving the notice and accompanying information, the Receiving Party may 28 produce the Nonparty’s confidential information responsive to the discovery request. If 10 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 the Nonparty timely seeks a protective order, the Receiving Party shall not produce any 2 information in its possession or control that is subject to the confidentiality agreement with 3 the Nonparty before a determination by the Court. Absent a court order to the contrary, 4 the Nonparty shall bear the burden and expense of seeking protection in this Court of its 5 Protected Material. 6 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 Protected Material to any person or in any circumstance not authorized under this 9 Stipulated Protective Order, the Receiving Party immediately must (1) notify in writing 10 the Designating Party of the unauthorized disclosures, (2) use its best efforts to retrieve all 11 unauthorized copies of the Protected Material, (3) inform the person or persons to whom 12 unauthorized disclosures were made of all the terms of this Stipulated Protective Order, 13 and (4) request such person or persons to execute the “Acknowledgment and Agreement 14 to be Bound” (Exhibit A). 15 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 PROTECTED MATERIAL 17 When a Producing Party gives notice to Receiving Parties that certain inadvertently 18 produced material is subject to a claim of privilege or other protection, the obligations of 19 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 20 This provision is not intended to modify whatever procedure may be established in an e21 discovery order that provides for production without prior privilege review. Pursuant to 22 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 23 effect of disclosure of a communication or information covered by the attorney-client 24 privilege or work product protection, the parties may incorporate their agreement in the 25 Stipulated Protective Order submitted to the Court. 26 13. MISCELLANEOUS 27 13.1. Right to Further Relief. 28 Nothing in this Stipulated Protective Order abridges the right of any person to seek 11 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 its modification by the Court in the future. 2 13.2. Right to Assert Other Objections. 3 By stipulating to the entry of this Stipulated Protective Order, no Party waives any 4 right it otherwise would have to object to disclosing or producing any information or item 5 on any ground not addressed in this Stipulated Protective Order. Similarly, no Party 6 waives any right to object on any ground to use in evidence of any of the material covered 7 by this Stipulated Protective Order. 8 13.3. Filing Protected Material. 9 A Party that seeks to file under seal any Protected Material must comply with Local 10 Rule 79-5. Protected Material may only be filed under seal pursuant to a court order 11 authorizing the sealing of the specific Protected Material at issue. If a Party's request to 12 file Protected Material under seal is denied by the Court, then the Receiving Party may file 13 the information in the public record unless otherwise instructed by the Court. 14 14. FINAL DISPOSITION 15 After the final disposition of this Action, within sixty (60) days of a written request 16 by the Designating Party, each Receiving Party must return all Protected Material to the 17 Producing Party or destroy such material. As used in this subdivision, “all Protected 18 Material” includes all copies, abstracts, compilations, summaries, and any other format 19 reproducing or capturing any of the Protected Material. Whether the Protected Material is 20 returned or destroyed, the Receiving Party must submit a written certification to the 21 Producing Party (and, if not the same person or entity, to the Designating Party) by the 6022 day deadline that (1) identifies (by category, where appropriate) all the Protected Material 23 that was returned or destroyed and (2) affirms that the Receiving Party has not retained 24 any copies, abstracts, compilations, summaries or any other format reproducing or 25 capturing any of the Protected Material. Notwithstanding this provision, Counsel is entitled 26 to retain an archival copy of all pleadings; motion papers; trial, deposition, and hearing 27 transcripts; legal memoranda; correspondence; deposition and trial exhibits; expert reports; 28 attorney work product; and consultant and expert work product, even if such materials 12 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 contain Protected Material. Any such archival copies that contain or constitute Protected 2 Material remain subject to this Stipulated Protective Order as set forth in Section 5. 3 15. VIOLATION 4 On noticed motion, the Court may enter an Order against any Party violating this 5 Stipulated Protective Order for an appropriate remedy in favor of the moving Party 6 including, without limitation, contempt proceedings and/or monetary sanctions. 7 8 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 9 10 DATED: June 7, 2021 Respectfully submitted, 11 DORSEY & WHITNEY LLP 12 13 By /s/ John T. Sullivan John T. Sullivan Erica H. Chen Melonie S. Jordan Attorneys for Defendant, Gebrüder Weiss, Inc. 14 15 16 17 DATED: June 7, 2021 Respectfully submitted, SMITH LC 18 19 By /s/ Stephanie P. Alexander Stephanie P. Alexander Douglas M. Campbell Attorneys for Plaintiff, Brian Thomassen 20 21 22 23 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED: 24 6/7/2021 25 Dated: _____________ 26 /s/ CHARLES F. EICK By: _______________________________ Magistrates Judge Charles F. Eick United States District Court Judge 27 28 13 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX) 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of [print or type full address], declare under penalty of perjury that I have read 4 5 in its entirety and understand the Stipulated Protective Order that was issue by the United 6 States District Court for the Central District of California on [DATE] in the case of Brian 7 Thomassen v. Gebrüder Weiss, Inc. Case No. 2:20-cv-8308 AB (Ex). I agree to comply 8 with and to be bound by all the terms of this Stipulated Protective Order and I understand 9 and acknowledge that failure to so comply could expose me to sanctions and punishment 10 in the nature of contempt. I solemnly promise that I will not disclose in any manner any 11 information or item that is subject to this Stipulated Protective Order to any person or 12 entity except in strict compliance with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court for 14 the Central District of California for the purpose of enforcing the terms of this Stipulated 15 Protective Order, even if such enforcement proceedings occur after termination of this 16 action. I hereby appoint 17 [print or type full name] of [print or type full address and telephone number] as my 18 California agent for service of process in connection with this action or any proceedings 19 related to enforcement of this Stipulated Protective Order. 20 21 22 Date: 23 City and State where sworn and signed: 24 Printed Name: 25 Signature: 26 27 28 14 STIPULATED PROTECTIVE ORDER CASE NO: 2:20-CV-08308 AB (EX)

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