Bernadette Paine v. Investment and Administrative Committee of The Walt Disney Company Sponsored Qualified Benefit Plans and Key Employees Deferred Compensation and Retirement Plan et al

Filing 96

PROTECTIVE ORDER by Magistrate Judge Karen L. Stevenson re Stipulation for Protective Order, 93 . (see document for details) (hr)

Download PDF
1 2 3 4 5 6 7 8 9 10 Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 11 12 13 14 Clarissa A. Kang, No. 210660 TRUCKER  HUSS A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, CA 94111 Telephone: (415) 788-3111 Facsimile: (415) 421-2017 E-mail: ckang@truckerhuss.com Brian D. Murray, No. 294100 TRUCKER  HUSS A Professional Corporation 15760 Ventura Blvd, Suite 910 Encino, CA 91436 Telephone: (213) 537-1016 Facsimile: (213) 537-1020 E-mail: bmurray@truckerhuss.com Attorneys for Defendants Investment and Administrative Committee of The Walt Disney Company Sponsored Qualified Benefit Plans and Key Employees Deferred Compensation and Retirement Plan; Twenty-First Century Fox, Inc.; and The Walt Disney Company 15 UNITED STATES DISTRICT COURT 16 CENTRAL DISTRICT OF CALIFORNIA 17 18 19 Bernadette Paine, an individual, Plaintiff, 20 21 22 23 24 25 26 vs. Case No. 2:20-CV-08610-VAP-KS STIPULATED PROTECTIVE ORDER Investment and Administrative Committee of The Walt Disney Company Sponsored Qualified Benefit Plans and Key Employees Deferred Compensation and Retirement Plan; Twenty-First Century Fox, Inc.; and The Walt Disney Company, Defendants. 27 28 -1PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 1 2 The parties hereto stipulate to the following form of protective order and request that the Court issue an order in this form: A. 4 Discovery in this action is likely to involve production of confidential, 5 proprietary, or private information for which special protection from public disclosure 6 and from use for any purpose other than prosecuting this litigation may be warranted. 7 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 8 Stipulated Protective Order. The parties acknowledge that this Order does not confer 9 blanket protections on all disclosures or responses to discovery and that the protection 10 it affords from public disclosure and use extends only to the limited information or 11 Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 3 PURPOSES AND LIMITATIONS items that are entitled to confidential treatment under the applicable legal principles. 12 The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated 13 Protective Order does not entitle them to file confidential information under seal; Civil 14 Local Rule 79-5 sets forth the procedures that must be followed and the standards that 15 will be applied when a party seeks permission from the court to file material under seal. 16 B. GOOD CAUSE STATEMENT 17 This action is likely to involve financial and commercial information 18 (implicating the privacy rights of third parties) for which special protection from public 19 disclosure and from use for any purpose other than prosecution of this action is 20 warranted. Such confidential information consists of, among other things, confidential 21 business or financial information, or commercial information (including information 22 implicating privacy rights of third parties), information otherwise generally unavailable 23 to the public, or which may be privileged or otherwise protected from disclosure under 24 state or federal statutes, court rules, case decisions, or common law. Accordingly, to 25 expedite the flow of information, to facilitate the prompt resolution of disputes over 26 confidentiality of discovery materials, to adequately protect information the parties are 27 entitled to keep confidential, to ensure that the parties are permitted reasonable 28 necessary uses of such material in preparation for and in the conduct of trial, to address -2PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 1 their handling at the end of the litigation, and serve the ends of justice, a protective 2 order for such information is justified in this matter. It is the intent of the parties that 3 information will not be designated as confidential for tactical reasons and that nothing 4 be so designated without a good faith belief that it has been maintained in a 5 confidential, non-public manner, and there is good cause why it should not be part of 6 the public record of this case. 7 2. 8 DEFINITIONS 2.1 Action: this action, Bernadette Paine, v. Investment and Administrative Committee of the Walt Disney Company Sponsored Qualified Benefit Plans and Key 10 Employees Deferred Compensation and Retirement Plan, et al., Case No. 2:20-CV- 11 Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 9 08610-VAP-KS. 12 2.2 13 14 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 15 it is generated, stored or maintained) or tangible things that qualify for protection under 16 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 17 Statement. 18 19 20 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 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL.” 23 2.6 Disclosure or Discovery Material: all items or information, regardless of 24 the medium or manner in which it is generated, stored, or maintained (including, among 25 other things, testimony, transcripts, and tangible things), that are produced or generated 26 in disclosures or responses to discovery in this matter. 27 28 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an -3PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 1 expert witness or as a consultant in this Action. 2.8 2 House Counsel: attorneys who are employees of a party to this Action. 3 House Counsel does not include Outside Counsel of Record or any other outside 4 counsel. 2.9 5 6 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 7 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 8 this Action but are retained to represent or advise a party to this Action and have 9 appeared in this Action on behalf of that party or are affiliated with a law firm which 10 has appeared on behalf of that party, and includes support staff. Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 11 2.11 Party: any party to this Action, including all of its officers, directors, 12 employees, consultants, retained experts, and Outside Counsel of Record (and their 13 support staffs). 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 14 15 Discovery Material in this Action. 16 2.13 Professional Vendors: persons or entities that provide litigation support 17 services (e.g., photocopying, videotaping, translating, preparing exhibits or 18 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 19 their employees and subcontractors. 2.14 Protected Material: any Disclosure or Discovery Material that is 20 21 designated as “CONFIDENTIAL.” 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 22 23 from a Producing Party. 24 3. SCOPE 25 The protections conferred by this Stipulation and Order cover not only Protected 26 Material (as defined above), but also (1) any information copied from Protected 27 Material or extracted from Protected Material; (2) all copies, excerpts, summaries, or 28 compilations of Protected Material; and (3) any testimony, conversations, or -4PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 1 presentations by Parties or their Counsel that reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the trial 2 3 judge. This Order does not govern the use of Protected Material at trial. 4 4. DURATION Even after final disposition of this litigation, the confidentiality obligations 6 imposed by this Order shall remain in effect until a Designating Party agrees otherwise 7 in writing or a court order otherwise directs. Final disposition shall be deemed to be 8 the later of (1) dismissal of all claims and defenses in this Action, with or without 9 prejudice; and (2) final judgment herein after the completion and exhaustion of all 10 appeals, rehearings, remands, trials, or reviews of this Action, including the time limits 11 Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 5 for filing any motions or applications for extension of time pursuant to applicable law. 12 5. 13 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 14 Each Party or Non-Party that designates information or items for protection under this 15 Order must take care to limit any such designation to specific material that qualifies 16 under the appropriate standards. The Designating Party must designate for protection 17 only those parts of material, documents, items, or oral or written communications that 18 qualify so that other portions of the material, documents, items, or communications for 19 which protection is not warranted are not swept unjustifiably within the ambit of this 20 Order. 21 Mass, indiscriminate, or routinized designations are prohibited. Designations 22 that are shown to be clearly unjustified or that have been made for an improper purpose 23 (e.g., to unnecessarily encumber the case development process or to impose 24 unnecessary expenses and burdens on other parties) may expose the Designating Party 25 to sanctions. 26 If it comes to a Designating Party’s attention that information or items that it 27 designated for protection do not qualify for protection, that Designating Party must 28 promptly notify all other Parties that it is withdrawing the inapplicable designation. -5PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 1 5.2 Manner and Timing of Designations. Except as otherwise provided in this 2 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 3 or ordered, Disclosure or Discovery Material that qualifies for protection under this 4 Order must be clearly so designated before the material is disclosed or produced. 5 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 7 documents, but excluding transcripts of depositions and other pretrial or trial 8 proceedings), that the Producing Party affix at a minimum, the legend 9 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 10 contains protected material. If only a portion or portions of the material on a page 11 Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 6 qualifies for protection, the Producing Party also must clearly identify the protected 12 portion(s) (e.g., by making appropriate markings in the margins). 13 A Party or Non-Party that makes original documents available for inspection 14 need not designate them for protection until after the inspecting Party has indicated 15 which documents it would like copied and produced. During the inspection and before 16 the designation, all of the material made available for inspection shall be deemed 17 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 18 copied and produced, the Producing Party must determine which documents, or 19 portions thereof, qualify for protection under this Order. Then, before producing the 20 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 21 to each page that contains Protected Material. If only a portion or portions of the 22 material on a page qualifies for protection, the Producing Party also must clearly 23 identify the protected portion(s) (e.g., by making appropriate markings in the margins). 24 (b) for testimony given in depositions that the Designating Party identify the 25 Disclosure or Discovery Material on the record, before the close of the deposition all 26 protected testimony or designate the portions of the transcript containing the Protected 27 Material as “CONFIDENTIAL.” 28 -6PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 1 (c) for information produced in some form other than documentary and for 2 any other tangible items, that the Producing Party affix in a prominent place on the 3 exterior of the container or containers in which the information is stored the legend 4 “CONFIDENTIAL.” If only a portion or portions of the information warrants 5 protection, the Producing Party, to the extent practicable, shall identify the protected 6 portion(s). 5.3 7 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate qualified information or items does not, standing alone, waive the 9 Designating Party’s right to secure protection under this Order for such material. Upon 10 timely correction of a designation, the Receiving Party must make reasonable efforts 11 Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 8 to assure that the material is treated in accordance with the provisions of this Order. 12 6. 13 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 14 designation of confidentiality at any time that is consistent with the Court’s Scheduling 15 Order. 16 17 18 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37.1 et seq. 6.3 The burden of persuasion in any such challenge proceeding shall be on the 19 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 20 to harass or impose unnecessary expenses and burdens on other parties) may expose 21 the Challenging Party to sanctions. Unless the Designating Party has waived or 22 withdrawn the confidentiality designation, all parties shall continue to afford the 23 material in question the level of protection to which it is entitled under the Producing 24 Party’s designation until the Court rules on the challenge. 25 6.4 The Parties agree that, notwithstanding any prior designation as 26 “CONFIDENTIAL,” minutes that have been produced in this action of any meeting of 27 the Investment and Administrative 28 Committee of The Walt Disney Company Sponsored Qualified Benefit Plans and Key -7PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 1 Employees Deferred Compensation and Retirement Plan (“Administrative 2 Committee”) or Subcommittee of the Administrative Committee (collectively, the 3 “Minutes”), and the information contained therein, need not be filed under seal in 4 connection with the filing of any document(s) in this Action and may be used, without 5 sealing, in any court proceeding in this Action. However, the Parties shall comply with 6 this Stipulated Protective Order in all other respects as to the Minutes. 7 8 9 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or produced by another Party or by a Non-Party in connection with this 11 Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 10 Action only for prosecuting, defending, or attempting to settle this Action. Such 12 Protected Material may be disclosed only to the categories of persons and under the 13 conditions described in this Order. When the Action has been terminated, a Receiving 14 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 15 Protected Material must be stored and maintained by a Receiving Party at a 16 location and in a secure manner that ensures that access is limited to the persons 17 authorized under this Order. 18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 19 Unless otherwise ordered by the court or permitted in writing by the 20 Designating Party, a Receiving Party may disclose any information or item 21 designated “CONFIDENTIAL” only to: 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 23 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 24 disclose the information for this Action; (b) the officers, directors, and employees (including House Counsel) of the 25 26 Receiving Party to whom disclosure is reasonably necessary for this Action; 27 28 -8PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 1 (c) Experts (as defined in this Order) of the Receiving Party to whom 2 disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (d) the court and its personnel; 5 (e) court reporters and their staff; 6 (f) professional jury or trial consultants, mock jurors, and Professional 7 Vendors to whom disclosure is reasonably necessary for this Action and who have 8 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (g) the author or recipient of a document containing the information or a 9 10 custodian or other person who otherwise possessed or knew the information; Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 11 (h) during their depositions, witnesses and attorneys for witnesses, in the 12 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 13 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 14 not be permitted to keep any confidential information unless they sign the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 16 by the Designating Party or ordered by the court. Pages of transcribed deposition 17 testimony or exhibits to depositions that disclose Protected Material may be separately 18 bound by the court reporter and may not be disclosed to anyone except as permitted 19 under this Stipulated Protective Order; and 20 (i) any mediator or settlement officer, and their supporting personnel, 21 mutually agreed upon by any of the parties engaged in settlement discussions. 22 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 23 OTHER LITIGATION 24 If a Party is served with a subpoena or a court order issued in other litigation that 25 compels disclosure of any information or items designated in this Action as 26 “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification shall 27 28 include a copy of the subpoena or court order; -9PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 1 (b) promptly notify in writing the party who caused the subpoena or order to 2 issue in the other litigation that some or all of the material covered by the subpoena or 3 order is subject to this Protective Order. Such notification shall include a copy of this 4 Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be pursued 5 6 by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with the 8 subpoena or court order shall not produce any information designated in this action as 9 “CONFIDENTIAL” before a determination by the court from which the subpoena or 10 order issued, unless the Party has obtained the Designating Party’s permission. The 11 Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 7 Designating Party shall bear the burden and expense of seeking protection in that court 12 of its confidential material and nothing in these provisions should be construed as 13 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 14 directive from another court. 15 9. 16 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 17 (a) The terms of this Order are applicable to information produced by a Non- 18 Party in this Action and designated as “CONFIDENTIAL.” Such information produced 19 by Non-Parties in connection with this litigation is protected by the remedies and relief 20 provided by this Order. Nothing in these provisions should be construed as prohibiting 21 a Non-Party from seeking additional protections. 22 (b) In the event that a Party is required, by a valid discovery request, to 23 produce a Non-Party’s confidential information in its possession, and the Party is 24 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 25 information, then the Party shall: 26 (1) promptly notify in writing the Requesting Party and the Non-Party 27 that some or all of the information requested is subject to a confidentiality agreement 28 with a Non-Party; -10PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 1 (2) promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this Action, the relevant discovery request(s), and a reasonably 3 specific description of the information requested; and (3) make the information requested available for inspection by the Non- 4 5 Party, if requested. (c) If the Non-Party fails to seek a protective order from this court within 14 7 days of receiving the notice and accompanying information, the Receiving Party may 8 produce the Non-Party’s confidential information responsive to the discovery request. 9 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 10 any information in its possession or control that is subject to the confidentiality 11 Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 6 agreement with the Non-Party before a determination by the court. Absent a court order 12 to the contrary, the Non-Party shall bear the burden and expense of seeking protection 13 in this court of its Protected Material. 14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 16 Protected Material to any person or in any circumstance not authorized under this 17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 18 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 19 all unauthorized copies of the Protected Material, (c) inform the person or persons to 20 whom unauthorized disclosures were made of all the terms of this Order, and (d) 21 request such person or persons to execute the “Acknowledgment and Agreement to Be 22 Bound” that is attached hereto as Exhibit A. 23 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 24 PROTECTED MATERIAL 25 When a Producing Party gives notice to Receiving Parties that certain 26 inadvertently produced material is subject to a claim of privilege or other protection, 27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 28 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure -11PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 1 may be established in an e-discovery order that provides for production without prior 2 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 3 parties reach an agreement on the effect of disclosure of a communication or 4 information covered by the attorney-client privilege or work product protection, the 5 parties may incorporate their agreement in the stipulated protective order submitted to 6 the court. 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 11 Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 10 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. 15 12.3 Filing Protected Material. A Party that seeks to file under seal any 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 specific 18 Protected Material at issue. If a Party's request to file Protected Material under seal is 19 denied by the court, then the Receiving Party may file the information in the public 20 record unless otherwise instructed by the court. 21 13. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in paragraph 4, within 90 23 days of a written request by the Designating Party, each Receiving Party must return 24 all Protected Material to the Producing Party or destroy such material. As used in this 25 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 26 summaries, and any other format reproducing or capturing any of the Protected 27 Material. Notwithstanding this provision, Counsel are entitled to retain an archival 28 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal -12PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 1 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 2 work product, and consultant and expert work product, even if such materials contain 3 Protected Material. Any such archival copies that contain or constitute Protected 4 Material remain subject to this Protective Order as set forth in Section 4 (DURATION). 5 14. 6 measures including, without limitation, contempt proceedings and/or monetary 7 sanctions. Any violation of this Order may be punished by any and all appropriate 8 9 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD 10 Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 11 DATED: March 23, 2022 GAROFOLO & RAMSDELL, LLP 12 13 By: 14 /s/ Craig P. Ramsdell Craig P. Ramsdell Joseph A. Garofolo 15 Attorneys for Plaintiff Bernadette Paine 16 17 DATED: March 23, 2022 TRUCKER  HUSS 18 By: __/s/ Clarissa A. Kang_______________ Clarissa A. Kang Brian D. Murray Attorneys for Defendants Investment and Administrative Committee of The Walt Disney Company Sponsored Qualified Benefit Plans and Key Employees Deferred Compensation and Retirement Plan; Twenty-First Century Fox, Inc.; and The Walt Disney Company 19 20 21 22 23 24 25 26 27 28 -13PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1 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 5 of perjury that I have read in its entirety and understand the Stipulated Protective Order 6 that was issued by the United States District Court for the Central District of California 7 on ________ [date] in the case of Bernadette Paine, v. Investment and Administrative 8 Committee of the Walt Disney Company Sponsored Qualified Benefit Plans and Key 9 Employees Deferred Compensation and Retirement Plan, et al., Case No. 2:20-CV- 10 08610-VAP-KS. I agree to comply with and to be bound by all the terms of this 11 Trucker  Huss A Professional Corporation One Embarcadero Center, 12th Floor San Francisco, California 94111 4 Stipulated Protective Order and I understand and acknowledge that failure to so comply 12 could expose me to sanctions and punishment in the nature of contempt. I solemnly 13 promise that I will not disclose in any manner any information or item that is subject 14 to this Stipulated Protective Order to any person or entity except in strict compliance 15 with the provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court 17 for the Central District of California for the purpose of enforcing the terms of this 18 Stipulated Protective Order, even if such enforcement proceedings occur after 19 termination of this action. I hereby appoint ___________________ [print or type full 20 name] of _____________________________________ [print or type full address and 21 telephone number] as my California agent for service of process in connection with 22 this action or any proceedings related to enforcement of this Stipulated Protective 23 Order. 24 Date: ______________ 25 City and State where sworn and signed: ___________________________ 26 Printed Name: 27 Signature: ________________________ ________________________ 28 -15PROTECTIVE ORDER; Case No: 2:20-CV-08610-VAP-KS 6915018.1

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?