Willie Thomas v. Nationwide Mutual Insurance Company

Filing 23

STIPULATED PROTECTIVE ORDER by Magistrate Judge Margo A. Rocconi re Stipulation for Protective Order 20 . (See document for details.) (es)

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1 2 3 4 5 6 7 MICHELLE R. BERNARD (SBN: 144582) mbernard@grsm.com JESSICA L. MEYER (SBN: 249064) jlmeyer@grsm.com GORDON REES SCULLY MANSUKHANI, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 Telephone: (619) 696-6700 Facsimile: (619) 696-7124 Attorneys for Defendant NATIONWIDE MUTUAL INSURANCE COMPANY 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 10 11 WILLIE THOMAS, 12 13 14 15 16 Plaintiff, v. NATIONWIDE MUTUAL INSURANCE COMPANY, an Ohio corporation, Defendant. 17 ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 2:21-cv-06296MWF-MAR Judge: Hon. Michael W. Fitzgerald Magistrate Judge: Hon. Margo A. Rocconi STIPULATED PROTECTIVE ORDER Complaint Filed: 8/4/2021 18 19 20 21 22 23 24 25 26 27 28 -1- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 1. INTRODUCTION A. 3 Discovery in this action is likely to involve production of confidential, 4 proprietary, or private information for which special protection from public 5 disclosure and from use for any purpose other than prosecuting this litigation may 6 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 7 enter the following Stipulated Protective Order. The parties acknowledge that this 8 Order does not confer blanket protections on all disclosures or responses to 9 discovery and that the protection it affords from public disclosure and use extends 10 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 2 PURPOSES AND LIMITATIONS only to the limited information or items that are entitled to confidential treatment 11 under the applicable legal principles. The parties further acknowledge, as set forth 12 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 13 file confidential information under seal; Civil Local Rule 79-5 sets forth the 14 procedures that must be followed and the standards that will be applied when a party 15 seeks permission from the court to file material under seal. 16 B. GOOD CAUSE STATEMENT 17 This action is likely to involve confidential, proprietary, and competitive 18 business information for which special protection from public disclosure and from 19 use for any purpose other than prosecution of this action is warranted. Such 20 confidential and proprietary materials and information consist of, among other things, 21 confidential medical information, confidential business or financial information, 22 information regarding confidential business practices, or other confidential research, 23 development, or commercial information (including information implicating privacy 24 rights of third parties), information otherwise generally unavailable to the public, or 25 which may be privileged or otherwise protected from disclosure under state or federal 26 statutes, court rules, case decisions, or common law. Accordingly, to expedite the 27 flow of information, to facilitate the prompt resolution of disputes over 28 confidentiality of discovery materials, to adequately protect information the parties -2- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 are entitled to keep confidential, to ensure that the parties are permitted reasonable 2 necessary uses of such material in preparation for and in the conduct of trial, to 3 address their handling at the end of the litigation, and serve the ends of justice, a 4 protective order for such information is justified in this matter. It is the intent of the 5 parties that information will not be designated as confidential for tactical reasons and 6 that nothing be so designated without a good faith belief that it has been maintained 7 in a confidential, non-public manner, and there is good cause why it should not be 8 part of the public record of this case. 9 2. Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 10 11 12 13 14 DEFINITIONS 2.1. Action: Thomas v. Nationwide Mutual Insurance Company, Case No. 2:21-cv-06296-MWF-MAR. 2.2. 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 15 how it is generated, stored or maintained) or tangible things that qualify for 16 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 17 the Good Cause 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 21 or 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 24 of the medium or manner in which it is generated, stored, or maintained (including, 25 among other things, testimony, transcripts, and tangible things), that are produced or 26 generated 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 -3- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 an 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 8 to 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 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 10 has appeared on behalf of that party, and includes support staff. 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. 2.13. Professional Vendors: 16 Persons or entities that provide litigation 17 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 18 demonstrations, and organizing, storing or retrieving data in any form or medium) 19 and their employees and subcontractors. 2.14. Protected Material: Any Disclosure or Discovery Material that is 20 21 designated as “CONFIDENTIAL.” 2.15. Receiving Party: 22 23 Material from a Producing Party. 24 3. A Party that receives Disclosure or Discovery SCOPE 25 The protections conferred by this Stipulation and Order cover not only 26 Protected Material (as defined above), but also (1) any information copied or 27 extracted from Protected Material; (2) all copies, excerpts, summaries, or 28 compilations of Protected Material; and (3) any testimony, conversations, or -4- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 presentations by Parties or their Counsel that might reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the 2 3 trial 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 7 otherwise in writing or a court order otherwise directs. Final disposition shall be 8 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 9 or without prejudice; and (2) final judgment herein after the completion and 10 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 5 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 11 including the time limits for filing any motions or applications for extension of time 12 pursuant to applicable law. 13 5. 14 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 15 Each Party or Non-Party that designates information or items for protection under 16 this Order must take care to limit any such designation to specific material that 17 qualifies under the appropriate standards. The Designating Party must designate for 18 protection only those parts of material, documents, items, or oral or written items, or 19 communications for which protection is not warranted are not swept unjustifiably 20 within the ambit of this 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 23 purpose (e.g., to unnecessarily encumber the case development process or to impose 24 unnecessary expenses and burdens on other parties) may expose the Designating 25 Party 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. -5- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 5.2 Manner and Timing of Designations. Except as otherwise provided in 2 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise 3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 4 under this Order must be clearly so designated before the material is disclosed or 5 produced. Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic documents, 8 but excluding transcripts of depositions or other pretrial or trial proceedings), that 9 the Producing Party affix at a minimum, the legend "CONFIDENTIAL" (hereinafter 10 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 6 "CONFIDENTIAL legend"), to each page that contains protected material. If only a 11 portion or portions of the material on a page qualifies for protection, the Producing 12 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 13 markings in the margins). 14 A Party or Non-Party that makes original documents available for inspection 15 need not designate them for protection until after the inspecting Party has indicated 16 which documents it would like copied and produced. During the inspection and 17 before the designation, all of the material made available for inspection shall be 18 deemed "CONFIDENTIAL." After the inspecting Party has identified the 19 documents it wants copied and produced, the Producing Party must determine which 20 documents, or portions thereof, qualify for protection under this Order. Then, before 21 producing the specified documents, the Producing Party must affix the 22 "CONFIDENTIAL legend" to each page that contains Protected Material. If only a 23 portion or portions of the material on a page qualifies for protection, the Producing 24 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 25 markings in the margins). 26 (b) for testimony given in depositions that the Designating Party identify 27 the Disclosure or Discovery Material on the record, before the close of the deposition 28 all protected testimony. -6- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR (c) 1 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 9 the Designating Party's right to secure protection under this Order for such material. 10 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 8 Upon timely correction of a designation, the Receiving Party must make reasonable 11 efforts to assure that the material is treated in accordance with the provisions of this 12 Order. 13 6. 14 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 15 designation of confidentiality at any time that is consistent with the Court’s 16 Scheduling Order. 17 18 19 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37.1, et seq. 6.3 Burden. The burden of persuasion in any such challenge 20 proceeding shall be on the Designating Party. Frivolous challenges, and those made 21 for an improper purpose (e.g., to harass or impose unnecessary expenses and burdens 22 on other parties) may expose the Challenging Party to sanctions. Unless the 23 Designating Party has waived or withdrawn the confidentiality designation, all 24 parties shall continue to afford the material in question the level of protection to 25 which it is entitled under the Producing Party's designation until the Court rules on 26 the challenge. 27 28 -7- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 2 7. ACCESS TO 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. 8 Protected Material must be stored and maintained by a Receiving Party at a 9 location and in a secure manner that ensures that access is limited to the persons Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 10 11 authorized under this Order. 7.2 Disclosure of “CONFIDENTIAL” information or Items. Unless 12 otherwise ordered by the court or permitted in writing by the Designated Party, a 13 Receiving 14 “CONFIDENTIAL” only to: 15 (a) Party may disclose any information or item designated the Receiving Party's Outside Counsel of Record in this Action, as well 16 as employees of said Outside Counsel of Record to whom it is reasonably necessary 17 to disclose the information for this Action; 18 19 20 (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 21 disclosure is reasonably necessary for this Action and who have signed the 22 "Acknowledgment and Agreement to Be Bound" (Exhibit A); 23 (d) the court and its personnel; 24 (e) court reporters and their staff; 25 (f) professional jury or trial consultants, mock jurors, and Professional 26 Vendors to whom disclosure is reasonably necessary for this Action and who have 27 signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A); 28 (g) the author or recipient of a document containing the information or a -8- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 custodian or other person who otherwise possessed or knew the information; (h) 2 during their depositions, witnesses, and attorneys for witnesses, in the 3 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 4 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 5 will not be permitted to keep any confidential information unless they sign the 6 "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise 7 agreed by the Designating Party or ordered by the court. Pages of transcribed 8 deposition testimony or exhibits to depositions that reveal Protected Material may 9 be separately bound by the court reporter and may not be disclosed to anyone except Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 10 as permitted under this Stipulated Protective Order; and (i) 11 any mediator or settlement officer, and their supporting personnel, 12 mutually agreed upon by any of the parties engaged in settlement discussions. 13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 14 PRODUCED IN OTHER LITIGATION 15 If a Party is served with a subpoena or a court ordered issued in other litigation 16 that compels disclosure of any information or items designated in this Action as 17 “CONFIDENTIAL,” that Party must: 18 19 20 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order 21 to issue in the other litigation that some or all of the material covered by the subpoena 22 or order is subject to this Protective Order. Such notification shall include a copy of 23 this Stipulated Protective Order; and 24 25 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 26 If the Designating Party timely seeks a protective order, the Party served with 27 the subpoena or court order shall not produce any information designated in this 28 action as "CONFIDENTIAL" before a determination by the court from which the -9- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 subpoena or order issued, unless the Party has obtained the Designating Party's 2 permission. The Designating Party shall bear the burden and expense of seeking 3 protection in that court of its confidential material and nothing in these provisions 4 should be construed as authorizing or encouraging a Receiving Party in this Action 5 to disobey a lawful directive from another court. 6 9. 7 PRODUCED IN THIS LITIGATION 8 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE (a) The terms of this Order are applicable to information produced by a Non-Party in this Action and designated as "CONFIDENTIAL." Such information 10 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 9 produced by Non-Parties in connection with this litigation is protected by the 11 remedies and relief provided by this Order. Nothing in these provisions should be 12 construed as prohibiting a Non-Party from seeking additional protections. 13 (b) In the event that a Party is required, by a valid discovery request, to 14 produce a Non-Party's confidential information in its possession, and the Party is 15 subject to an agreement with the Non-Party not to produce the Non-Party's 16 confidential information, then the Party shall: 17 (1) promptly notify in writing the Requesting Party and the Non-Party that 18 some or all of the information requested is subject to a confidentiality 19 agreement with a Non-Party; 20 (2) 21 Protective Order in this Action, the relevant discovery request(s), and a 22 reasonably specific description of the information requested; and 23 (3) 24 Party, if requested. 25 (c) If the Non-Party fails to seek a protective order from this court within 14 26 days of receiving the notice and accompanying information, the Receiving Party 27 may produce the Non-Party's confidential information responsive to the discovery 28 request. If the Non-Party timely seeks a protective order, the Receiving Party shall promptly provide the Non-Party with a copy of the Stipulated make the information requested available for inspection by the Non- -10- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 not produce any information in its possession or control that is subject to the 2 confidentiality agreement with the Non-Party before a determination by the court. 3 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 4 of seeking protection in this court of its Protected Material. 5 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 7 Protected Material to any person or in any circumstance not authorized under this 8 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 9 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 10 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person 11 or persons to whom unauthorized disclosures were made of all the terms of this 12 Order, and (d) request such person or persons to execute the “Acknowledgment and 13 Agreement to Be Bound” attached hereto as Exhibit A. 14 11. 15 PROTECTED MATERIAL INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 When a Producing Party gives notice to Receiving Parties that certain 17 inadvertently produced material is subject to a claim of privilege or other protection, 18 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 19 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 20 may be established in an e-discovery order that provides for production without prior 21 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 22 parties reach an agreement on the effect of disclosure of a communication or 23 information covered by the attorney-client privilege or work product protection, the 24 parties may incorporate their agreement in the stipulated protective order submitted 25 to the court. 26 12. 27 28 MISCELLANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the Court in the future. -11- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 12.2 Right to Assert Other Objections. By stipulating to the entry of this 2 Protective Order no Party waives any right it otherwise would have to object to 3 disclosing or producing any information or item on any ground not addressed in this 4 Stipulated Protective Order. Similarly, no Party waives any right to object on any 5 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 7 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 8 only be filed under seal pursuant to a court order authorizing the sealing of the 9 specific Protected Material at issue. If a Party's request to file Protected Material 10 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 6 under seal is denied by the court, then the Receiving Party may file the information 11 in the public record unless otherwise instructed by the court. 12 13. FINAL DISPOSITION 13 After the final disposition of this Action, as defined in Section 4, within 60 14 days of a written request by the Designating Party, each Receiving Party must return 15 all Protected Material to the Producing Party or destroy such material. As used in 16 this subdivision, "all Protected Material" includes all copies, abstracts, compilations 17 summaries, and any other format reproducing or capturing any of the Protected 18 Material. Whether the Protected Material is returned or destroyed, the Receiving 19 Party must submit a written certification to the Producing Party (and, if not the same 20 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 21 (by category, where appropriate) all the Protected Material that was returned or 22 destroyed and (2) affirms that the Receiving Party has not retained any copies, 23 abstracts, compilations, summaries or any other format reproducing or capturing any 24 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 25 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 26 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 27 reports, attorney work product, and consultant and expert work product, even if such 28 materials contain Protected Material. Any such archival copies that contain or -12- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 constitute Protected Material remain subject to this Protective Order as set forth in 2 Section 4 (DURATION). 3 14. VIOLATION 4 Any violation of this Order may be punished by any and all appropriate 5 measuring including, without limitation, contempt proceedings and/or monetary 6 sanctions. 7 8 IT IS HEREBY STIPULATED AND AGREED. 9 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 10 Dated: November 15, 2021 11 By: s / Hannah Fernandez Ognian Gavrilov Hannah Fernandez Attorneys for Plaintiff WILLIE THOMAS 12 13 14 15 GAVRILOV & BROOKS Dated: November 15, 2021 16 17 GORDON REES SCULLY MANSUKHANI, LLP By: /s/ Michelle R. Bernard Michelle R. Bernard Jessica L. Meyer Attorneys for Defendant NATIONWIDE MUTUAL INSURANCE COMPANY 18 19 20 21 22 23 24 25 26 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED Dated: 11/19/21 H Hon. M Margo A R A. Rocconi i UNITED STATES MAGISTRATE JUDGE 27 28 -13- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 SIGNATURE CERTIFICATION 2 3 I hereby certify that the content of this document is acceptable to Hannah 4 Fernandez, counsel for Plaintiff, and that I have obtained Ms. Fernandez’s 5 authorization to affix her electronic signature to this document. 6 /s/ Michelle R. Bernard Michelle R. Bernard 7 8 9 10 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -14- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR 1 Exhibit A 2 Acknowledgment and Agreement to Be Bound 3 I, , do solemnly swear that I am fully familiar with the terms of the Protective Order Concerning Confidential Information entered 5 in Thomas v. Nationwide Mutual Insurance Company, et al., United States District 6 Court for the Central District of California, Civil Action No. 2:21-cv-06296-MWF- 7 MAR, and hereby agree to comply with and be bound by the terms and conditions 8 of said Order unless and until modified by further Order of the Court. I understand 9 and acknowledge that failure to so comply could expose me to sanctions and 10 punishment in the nature of contempt. I hereby consent to the jurisdiction of the 11 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 4 Court for purposes of enforcing this agreement. 12 13 14 Dated: [Name of Signator Typed] 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1245939/62666347v.2 -15- STIPULATED PROTECTIVE ORDER Case No. 2:21-cv-06296-MWF-MAR

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