Shenzhen Yapu Tech. Co., Ltd. et al v. Integrated Viral Protection Solutions, LLC et al

Filing 38

STIPULATED PROTECTIVE ORDER by Magistrate Judge Jean P. Rosenbluth re Stipulation for Protective Order 35 . See Order for details. (es)

1
2
3
4
5
6
7
8
9

ANDREW D. FORTNEY (SBN 178699)
CENTRAL CALIFORNIA IP GROUP, P.C.
1768 E. Birch Ave.
Fresno, CA 93720
Telephone: [phone]
Email: [e-mail]
Attorney for Plaintiffs
SHENZHEN YAPU TECH. CO., LTD. and
SICHUAN WURUI TECH. CO., LTD.
Additional counsel listed on following page

10
11

UNITED STATES DISTRICT COURT

12

CENTRAL DISTRICT OF CALIFORNIA

13
14
15
16

SHENZHEN YAPU TECH. CO.,
LTD. and SICHUAN WURUI TECH.
CO., LTD.,
Plaintiffs,

17
18
19
20
21
22

v.
INTEGRATED VIRAL
PROTECTION SOLUTIONS LLC
and MEDISTAR CORPORATION,
Defendants.

23
24
25
26
27
28
040661-000000 8641063.1

Case No. 2:22-cv-1403 GW(JPRx)
STIPULATED PROTECTIVE
ORDER

1
2
3
4
5
6
7
8
9

MCCORMICK, BARSTOW, SHEPPARD,
WAYTE & CARRUTH LLP
GREGORY S. MASON, #148997
[e-mail]
7647 North Fresno Street
Fresno, California 93720
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
INTEGRATED VIRAL PROTECTION
SOLUTIONS LLC and MEDISTAR
CORPORATION

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

040661-000000 8641063.1

Stipulated Protective Order

2

Case No. 2:22-cv-1403 GW(JPRx)

1

1.

INTRODUCTION

2

1.1

PURPOSES AND LIMITATIONS

3

Discovery in this action may involve production of confidential, proprietary,

4

or private information for which special protection from public disclosure and from

5

use for any purpose other than prosecuting this litigation may be warranted.

6

Pursuant to the Court’s Order of September 8, 2022, the Parties hereby stipulate to

7

and petition the Court to enter the following Stipulated Protective Order. The

8

Parties acknowledge that this Order does not confer blanket protections on all

9

disclosures or responses to discovery and that the protection it affords from public

10

disclosure and use extends only to the limited information or items that are entitled

11

to confidential treatment under the applicable legal principles. The Parties further

12

acknowledge, as set forth in Section 12.3 below, that this Order does not entitle

13

them to 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

1.2

GOOD CAUSE STATEMENT

17

The Parties contend that they have trade secrets and other confidential or

18

proprietary information, that are, or at least may be, subject to reasonable efforts by

19

the Party to maintain their secrecy, confidentiality and/or proprietary nature, and

20

that may have value to the Party (for example, by virtue of not being generally

21

known). Each of the Parties anticipates producing documents and providing oral

22

testimony that may include such trade secrets and confidential or proprietary

23

information in this case. For example, a primary issue in this case is breach of

24

contract related to the alleged non-payment by Defendants for the manufacture and

25

sale of air purifiers. The contract includes terms that Plaintiffs contend are not

26

generally known to the public, and that Plaintiffs wish to keep secret or confidential.

27

The air purifiers were manufactured by Plaintiffs according to designs and

28

040661-000000 8641063.1

Stipulated Protective Order

3

Case No. 2:22-cv-1403 GW(JPRx)

1

manufacturing flows that Plaintiffs contend are not generally known to the public,

2

and that the Plaintiffs wish to keep secret or confidential. As another example, in its

3

counterclaims, IVP has alleged it has incurred damages related to nonconforming

4

and nonperforming air purifiers provided by at least one of the Plaintiffs. IVP

5

anticipates that there may be disclosures of information to support its damages

6

claims that may not be generally known, and may be regarded as confidential.
This is not an exhaustive list of the potential trade secrets and confidential /

7
8

proprietary information that may be disclosed during discovery, but the Parties

9

believe it is sufficient to justify this Protective Order.

10
11

2.

DEFINITIONS
2.1

Action: This action, captioned SHENZHEN YAPU TECH. CO., LTD.

12

and SICHUAN WURUI TECH. CO., LTD. v. INTEGRATED VIRAL

13

PROTECTION SOLUTIONS LLC and MEDISTAR CORPORATION, Case No.

14

2:22-cv-1403 GW(JPRx).

15
16
17

2.2

Challenging Party: a Party or Nonparty that challenges the designation

of information or items under this Order.
2.3

“CONFIDENTIAL” Information or Items: information (regardless of

18

how it is generated, stored, or maintained) or tangible things that qualify for

19

protection under Federal Rule of Civil Procedure 26(c) and as specified above in the

20

Good Cause Statement.

21
22
23

2.4

Counsel: Outside Counsel of Record and House Counsel (as well as

their support staff).
2.5

Designating Party: a Party or Nonparty that designates information or

24

items that it produces in disclosures or in responses to discovery as

25

“CONFIDENTIAL.”

26

2.6

Disclosure or Discovery Material: all items or information, regardless

27

of the medium or manner in which it is generated, stored, or maintained (including,

28

040661-000000 8641063.1

Stipulated Protective Order

4

Case No. 2:22-cv-1403 GW(JPRx)

1

among other things, testimony, transcripts, and tangible things), that are produced or

2

generated in disclosures or responses to discovery in this matter.

3

2.7

Expert: a person with specialized knowledge or experience in a matter

4

pertinent to the litigation who has been retained by a Party or its counsel to serve as

5

an expert witness or as a consultant in this action.

6

2.8

House Counsel: attorneys who are employees of a Party to this Action.

7

House Counsel does not include Outside Counsel of Record or any other outside

8

counsel.

9
10

2.9

Nonparty: any natural person, partnership, corporation, association, or

other legal entity not named as a Party to this action.

11

2.10 Outside Counsel of Record: attorneys who are not employees of a

12

Party to this Action but are retained to represent or advise a Party and have appeared

13

in this Action on behalf of that Party or are affiliated with a law firm that has

14

appeared on behalf of that Party, including support staff.

15

2.11 Party: any Party to this Action, including all of its officers, directors,

16

employees, consultants, retained experts, and Outside Counsel of Record (and their

17

support staffs).

18
19
20

2.12 Producing Party: a Party or Nonparty that produces Disclosure or
Discovery Material in this Action.
2.13 Professional Vendors: persons or entities that provide litigation

21

support services (for example, photocopying, videotaping, translating, preparing

22

exhibits or demonstrations, and organizing, storing, or retrieving data in any form or

23

medium) and their employees and subcontractors.

24
25
26

2.14 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery

27

Material from a Producing Party.

28

040661-000000 8641063.1

Stipulated Protective Order

5

Case No. 2:22-cv-1403 GW(JPRx)

1

3.

SCOPE

2

The protections conferred by this Stipulation and Order cover not only

3

Protected Material (as defined above) but also any information copied or extracted

4

from Protected Material; all copies, excerpts, summaries, or compilations of

5

Protected Material; and any testimony, conversations, or presentations by Parties or

6

their Counsel that might reveal Protected Material.
Any use of Protected Material at trial will be governed by the orders of the

7
8

trial judge. This Order does not govern the use of Protected Material at trial.

9

4.

DURATION
Once a case proceeds to trial, all the information that was designated as

10
11

confidential or maintained under this Order becomes public and will be

12

presumptively available to all members of the public, including the press, unless the

13

trial judge finds compelling reasons to proceed otherwise. See Kamakana v. City &

14

Cnty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good

15

cause” showing for sealing documents produced in discovery from “compelling

16

reasons” needed for merits-related documents). Accordingly, the terms of this

17

Order do not extend beyond the beginning of trial.
Even after final disposition of this litigation, the confidentiality obligations

18
19

imposed by this Order will remain in effect until a Designating Party agrees

20

otherwise in writing or a court order otherwise directs. Final disposition is the later

21

of (1) dismissal of all claims and defenses in this Action, with or without prejudice,

22

or (2) final judgment after the completion and exhaustion of all appeals, rehearings,

23

remands, trials, or reviews of this Action, including the time limits for filing any

24

motions or applications for extension of time under applicable law.

25

5.

26

DESIGNATING PROTECTED MATERIAL
5.1

Each Party or Nonparty that designates information or items for

27

protection under this Order must take care to limit any such designation to specific

28

040661-000000 8641063.1

Stipulated Protective Order

6

Case No. 2:22-cv-1403 GW(JPRx)

1

material that qualifies under the appropriate standards. The Designating Party must

2

designate for protection only those parts of material, documents, items, or oral or

3

written communications that qualify so that other portions of the material,

4

documents, items, or communications for which protection is not warranted are not

5

swept unjustifiably within the ambit of this Order.

6

Mass, indiscriminate, or routinized designations are prohibited. Designations

7

that are shown to be clearly unjustified or that have been made for an improper

8

purpose (for example, to unnecessarily encumber the case-development process or

9

to impose unnecessary expenses and burdens on other parties) may expose the

10

Designating Party to sanctions.

11

If it comes to a Designating Party’s attention that information or items it

12

designated for protection do not qualify for that level of protection, that Designating

13

Party must promptly notify all other Parties that it is withdrawing the inapplicable

14

designation.

15

5.2

Except as otherwise provided in this Order, Disclosure or Discovery

16

Material that qualifies for protection under this Order must be clearly so designated

17

before the material is disclosed or produced.

18

Designation in conformity with this Order requires the following:

19

(a) for information in documentary form (for example, paper or electronic

20

documents but excluding transcripts of depositions or other pretrial or trial

21

proceedings), the Producing Party must affix at a minimum the legend

22

“CONFIDENTIAL” to each page that contains Protected Material. If only a portion

23

or portions of the material on a page qualify for protection, the Producing Party

24

must clearly identify the protected portion(s) (for example, by making appropriate

25

markings in the margins).

26

A Party or Nonparty that makes original documents available for

27

inspection need not designate them for protection until after the inspecting Party has

28

040661-000000 8641063.1

Stipulated Protective Order

7

Case No. 2:22-cv-1403 GW(JPRx)

1

indicated which documents it would like copied and produced. During the

2

inspection and before the designation, all material made available for inspection

3

must be treated as “CONFIDENTIAL.” After the inspecting Party has identified the

4

documents it wants copied and produced, the Producing Party must determine which

5

documents, or portions thereof, qualify for protection under this Order. Then,

6

before producing the specified documents, the Producing Party must affix the

7

“CONFIDENTIAL” legend to each page that contains Protected Material. If only a

8

portion or portions of the material on a page qualify for protection, the Producing

9

Party also must clearly identify the protected portion(s) (for example, by making

10

appropriate markings in the margins).
(b) for testimony given in depositions, the Designating Party must identify

11
12

the Disclosure or Discovery Material that is protected on the record, before the close

13

of the deposition.
(c) for information produced in some form other than documentary and for

14
15

any other tangible items, the Producing Party must affix in a prominent place on the

16

exterior of the container or containers in which the information is stored the legend

17

“CONFIDENTIAL.” If only a portion or portions of the information warrant

18

protection, the Producing Party, to the extent practicable, must identify the protected

19

portion(s).
5.3

20

If timely corrected, an inadvertent failure to designate qualified

21

information or items does not, standing alone, waive the Designating Party’s right to

22

secure protection under this Order for that material. On timely correction of a

23

designation, the Receiving Party must make reasonable efforts to assure that the

24

material is treated in accordance with the provisions of this Order.

25

6.

26

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Any Party or Nonparty may challenge a designation of confidentiality

27

at any time consistent with the Court’s scheduling order.

28

040661-000000 8641063.1

Stipulated Protective Order

8

Case No. 2:22-cv-1403 GW(JPRx)

6.2

1
2

The Challenging Party must initiate the dispute-resolution process (and,

if necessary, file a discovery motion) under Local Rule 37.
6.3

3

The burden of persuasion in any such proceeding is on the Designating

4

Party. Frivolous challenges, and those made for an improper purpose (for example,

5

to harass or impose unnecessary expenses and burdens on other parties), may expose

6

the Challenging Party to sanctions. Unless the Designating Party has waived or

7

withdrawn the confidentiality designation, all parties must continue to afford the

8

material in question the level of protection to which it is entitled under the

9

Producing Party’s designation until the Court rules on the challenge.

10
11

7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

A Receiving Party may use Protected Material that is disclosed or

12

produced by another Party or by a Nonparty in connection with this Action only for

13

prosecuting, defending, or attempting to settle this Action. Such Protected Material

14

may be disclosed only to the categories of people and under the conditions described

15

in this Order. When the Action has been terminated, a Receiving Party must comply

16

with the provisions of Section 13 below (FINAL DISPOSITION).

17

Protected Material must be stored and maintained by a Receiving Party at a

18

location and in a manner sufficiently secure to ensure that access is limited to the

19

people authorized under this Order.

20

7.2

Unless otherwise ordered by the Court or permitted in writing by the

21

Designating Party, a Receiving Party may disclose any information or item

22

designated “CONFIDENTIAL” only to the following people:

23

(a) the Receiving Party’s Outside Counsel of Record in this Action, as

24

well as employees of that Outside Counsel of Record to whom it is reasonably

25

necessary to disclose the information for this Action;

26

(b) the officers, directors, and employees (including House Counsel) of

27

the Receiving Party to whom disclosure is reasonably necessary for this Action;

28

040661-000000 8641063.1

Stipulated Protective Order

9

Case No. 2:22-cv-1403 GW(JPRx)

(c) Experts (as defined in this Order) of the Receiving Party to whom

1
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;
(h) during their depositions, witnesses and attorneys for witnesses to

11
12

whom disclosure is reasonably necessary, provided that the deposing party requests

13

that the witness sign the form attached as Exhibit A hereto and the witnesses will

14

not be permitted to keep any confidential information unless they sign the form,

15

unless otherwise agreed by the Designating Party or ordered by the Court. Pages of

16

transcribed deposition testimony or exhibits to depositions that reveal Protected

17

Material may be separately bound by the court reporter and may not be disclosed to

18

anyone except as permitted under this Order; and
(i) any mediator or settlement officer, and their supporting personnel,

19
20

mutually agreed on by any of the Parties engaged in settlement discussions or

21

appointed by the Court.

22

8.

23

IN OTHER LITIGATION

24

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
If a Party is served with a subpoena or a court order issued in other litigation

25

that compels disclosure of any information or items designated in this Action as

26

“CONFIDENTIAL,” that Party must

27
28

040661-000000 8641063.1

Stipulated Protective Order

10

Case No. 2:22-cv-1403 GW(JPRx)

(a) promptly notify in writing the Designating Party. Such notification

1
2

must include a copy of the subpoena or court order unless prohibited by law;
(b) promptly notify in writing the party who caused the subpoena or order

3
4

to issue in the other litigation that some or all of the material covered by the

5

subpoena or order is subject to this Protective Order. Such notification must include

6

a copy of this Order; and
(c) cooperate with respect to all reasonable procedures sought to be

7
8

pursued by the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with

9
10

the subpoena or court order should not produce any information designated in this

11

action as “CONFIDENTIAL” before a determination on the protective-order request

12

by the relevant court unless the Party has obtained the Designating Party’s

13

permission. The Designating Party bears the burden and expense of seeking

14

protection of its Confidential Material, and nothing in these provisions should be

15

construed as authorizing or encouraging a Receiving Party in this Action to disobey

16

a lawful directive from another court.

17

9.

18

PRODUCED IN THIS LITIGATION

19

A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE
(a) The terms of this Order are applicable to information produced by a

20

Nonparty in this Action and designated as “CONFIDENTIAL.” Such information is

21

protected by the remedies and relief provided by this Order. Nothing in these

22

provisions should be construed as prohibiting a Nonparty from seeking additional

23

protections.

24

(b) In the event that a Party is required by a valid discovery request to

25

produce a Nonparty’s Confidential Information in its possession and the Party is

26

subject to an agreement with the Nonparty not to produce the Nonparty’s

27

Confidential Information, then the Party must

28

040661-000000 8641063.1

Stipulated Protective Order

11

Case No. 2:22-cv-1403 GW(JPRx)

(1) promptly notify in writing the Requesting Party and the Nonparty

1
2

that some or all of the information requested is subject to a confidentiality

3

agreement with a Nonparty;
(2) promptly provide the Nonparty with a copy of this Order, the

4
5

relevant discovery request(s), and a reasonably specific description of the

6

information requested; and
(3) make the information requested available for inspection by the

7
8

Nonparty, if requested.

9

(c) If the Nonparty fails to seek a protective order within 21 days of

10

receiving the notice and accompanying information, the Receiving Party may

11

produce the Nonparty’s Confidential Information responsive to the discovery

12

request. If the Nonparty timely seeks a protective order, the Receiving Party must

13

not produce any information in its possession or control that is subject to the

14

confidentiality agreement with the Nonparty before a ruling on the protective-order

15

request. Absent a court order to the contrary, the Nonparty must bear the burden

16

and expense of seeking protection of its Protected Material.

17

10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that by inadvertence or otherwise, it has disclosed

18
19

Protected Material to any person or in any circumstance not authorized under this

20

Order, the Receiving Party must immediately notify the Designating Party in writing

21

of the unauthorized disclosures, use its best efforts to retrieve all unauthorized

22

copies of the Protected Material, inform the person or people to whom unauthorized

23

disclosures were made of the terms of this Order, and ask that person or people to

24

execute the “Acknowledgment and Agreement to Be Bound” that is attached hereto

25

as Exhibit A.

26

11.

27

PROTECTED MATERIAL

28

040661-000000 8641063.1

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

Stipulated Protective Order

12

Case No. 2:22-cv-1403 GW(JPRx)

When a Producing Party gives notice to Receiving Parties that certain

1
2

inadvertently produced material is subject to a claim of privilege or other protection,

3

the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

4

Procedure 26(b)(5)(B).

5

12.

12.1 Nothing in this Order abridges the right of any person to seek its

6
7

MISCELLANEOUS

modification by the Court.
12.2 By stipulating to the entry of this Order, no Party waives any right it

8
9

otherwise would have to object to disclosing or producing any information or item

10

on any ground not addressed in this Order. Similarly, no Party waives any right to

11

object on any ground to use in evidence of any of the material covered by this

12

Order.

13

12.3 A Party that seeks to file under seal any Protected Material must

14

comply with Civil Local Rule 79-5. Protected Material may be filed under seal only

15

pursuant to a court order authorizing the sealing of the specific Protected Material at

16

issue. If a Party's request to file Protected Material under seal is denied, then the

17

Receiving Party may file the information in the public record unless otherwise

18

instructed by the Court.

19

13.

20

FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4, within 60

21

days of a written request by the Designating Party, each Receiving Party must return

22

all Protected Material to the Producing Party or destroy such material. As used in

23

this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

24

summaries, and any other format reproducing or capturing any of the Protected

25

Material. Whether the Protected Material is returned or destroyed, the Receiving

26

Party must submit a written certification to the Producing Party (and, if not the same

27

person or entity, to the Designating Party) by the 60-day deadline that identifies (by

28

040661-000000 8641063.1

Stipulated Protective Order

13

Case No. 2:22-cv-1403 GW(JPRx)

1

category, when appropriate) all the Protected Material that was returned or

2

destroyed and affirms that the Receiving Party has not retained any copies, abstracts,

3

compilations, summaries, or any other format reproducing or capturing any of the

4

Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

5

archival copy of all pleadings; motion papers; trial, deposition, and hearing

6

transcripts; legal memoranda; correspondence; deposition and trial exhibits; expert

7

reports; attorney work product; and consultant and expert work product even if such

8

materials contain Protected Material. Any such archival copies that contain or

9

constitute Protected Material remain subject to this Order as set forth in Section 4

10

(DURATION).

11

14.

SANCTIONS

12

Any willful violation of this Order may be punished by civil or criminal

13

contempt, financial or evidentiary sanctions, reference to disciplinary authorities, or

14

other appropriate action at the discretion of the Court.

15
16
17
18
19
20
21
22
23
24
25
26
27
28

040661-000000 8641063.1

Stipulated Protective Order

14

Case No. 2:22-cv-1403 GW(JPRx)

1

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

2
3

DATED: September 15, 2022

/s/Andrew D. Fortney
CENTRAL CALIFORNIA IP GROUP,
P.C.
ANDREW D. FORTNEY
Attorney for Plaintiffs
SHENZHEN YAPU TECH. CO., LTD.
and SICHUAN WURUI TECH. CO., LTD.

DATED: September 15, 2022

/s/Gregory S. Mason
MCCORMICK, BARSTOW,
SHEPPARD, WAYTE & CARRUTH
LLP
GREGORY S. MASON
Attorney for Defendants
INTEGRATED VIRAL PROTECTION
SOLUTIONS LLC and MEDISTAR
CORPORATION

4
5
6
7
8
9
10
11
12
13
14
15
16
17

DATED: September 16, 2022

18
19
20
21

JEAN P. ROSENBLUTH
U.S. MAGISTRATE JUDGE

22
23
24
25
26
27
28

040661-000000 8641063.1

Stipulated Protective Order

15

Case No. 2:22-cv-1403 GW(JPRx)

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 have read in its entirety and

6

understand the Stipulated Protective Order that was issued by the U.S. District Court

7

for the Central District of California on [date] in the case of ___________ [insert

8

case name and number]. I agree to comply with and to be bound by all terms of

9

this Stipulated Protective Order, and I understand and acknowledge that failure to so

10

comply could expose me to sanctions and punishment, including contempt. I

11

solemnly promise that I will not disclose in any manner any information or item that

12

is subject to this Stipulated Protective Order to any person or entity except in strict

13

compliance with the provisions of this Order.

14

I further agree to submit to the jurisdiction of the U.S. District Court for the

15

Central District of California for the purpose of enforcing the terms of this

16

Stipulated Protective Order, even if such enforcement proceedings occur after

17

termination of this action. I hereby appoint __________________________ [full

18

name] of _______________________________________ [full address and

19

telephone number] as my California agent for service of process in connection with

20

this action or any proceedings related to enforcement of this Stipulated Protective

21

Order.

22

Date: ______________________________________

23

City and State where signed: _________________________________

24
25

Printed name: _______________________________

26
27

Signature: __________________________________

28

040661-000000 8641063.1

Stipulated Protective Order

16

Case No. 2:22-cv-1403 GW(JPRx)

1

ATTESTATION

2
3
4
5
6
7
8

I, Gregory S. Mason, hereby attest, pursuant to C.D. Cal. Civil Local Rule 54.3.4(a)(2)(i), that the concurrence to the filing of this document has been obtained
from each signatory hereto.
Dated: September 15, 2022

By /s/Gregory S. Mason
Gregory S. Mason

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

040661-000000 8641063.1

Stipulated Protective Order

17

Case No. 2:22-cv-1403 GW(JPRx)

CERTIFICATE OF SERVICE

1
2
3

I hereby certify that on September 15, 2022, I caused the foregoing

4

STIPULATED PROTECTIVE ORDER to be served upon all counsel of record in

5

this action through the Court’s CM/ECF System.

6
7

Dated: September 15, 2022

/s/Gregory S. Mason
Gregory S. Mason

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

040661-000000 8641063.1

Stipulated Protective Order

18

Case No. 2:22-cv-1403 GW(JPRx)