Michael Sinel v. Genexa, Inc. et al

Filing 30

STIPULATED PROTECTIVE ORDER by Magistrate Judge Maria A. Audero re Stipulation for Protective Order 29 . See Order for details. (es)

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1 Wendy M. Thomas (SBN 268695) E: wendyt@ttelawgroup.com 2 Betty Huynh (SBN 315880) E: bettyh@ttelawgroup.com 3 Justin Rhee (SBN 340300) E: justinr@ttelawgroup.com 4 TADJEDIN THOMAS & ENGBLOOM LAW GROUP LLP 5 6101 West Centinela Avenue, Suite 270 Culver City, CA 90230 6 T: (310) 362-4970 7 Attorneys for Defendants Genexa, Inc., Max Spielberg, and David Johnson 8 9 10 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION 11 MICHAEL SINEL, an individual, CASE NO: 2:22-cv-03961-FMO-MAA 12 [Lower Court Case No.: 21SMCV01977 Los Angeles County Superior Court, Santa Monica Courthouse] 13 Plaintiff, v. 14 GENEXA, INC., a Delaware corporation; MAX SPIELBERG, an individual; DAVID STIPULATED PROTECTIVE 15 JOHNSON, an individual; and DOES 1 ORDER through 50, inclusive, 16 Defendants 17 Judge: Hon. Fernando M. Olguin 18 GENEXA, INC., a Delaware corporation; Dept.: 6D MAX SPIELBERG, an individual; DAVID 19 JOHNSON, an individual; Complaint Filed: December 20, 2021 20 Counter-Claimants. First Amended Complaint Filed: 21 v. May 16, 2022 22 MICHAEL SINEL, an individual, and MSSMD INVESTMENTS, INC., a 23 Delaware Corporation, and MOES 1 through 20, 24 Counter-Defendants. 25 26 I. Trial Date: None Set PURPOSES AND LIMITATIONS 27 Discovery in this action is likely to involve production of confidential, proprietary, or 28 private information for which special protection from public disclosure and from use 1 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 for any purpose other than prosecuting this litigation may be warranted. Accordingly, 2 the parties hereby stipulate to and petition the Court to enter the following Stipulated 3 Protective Order. The parties acknowledge that this Order does not confer blanket 4 protections on all disclosures or responses to discovery and that the protection it affords 5 from public disclosure and use extends only to the limited information or items that are 6 entitled to confidential treatment under the applicable legal principles. The parties 7 further acknowledge, as set forth in Section XIII(C), below, that this Stipulated 8 Protective Order does not entitle them to file confidential information under seal; Civil 9 Local Rule 79-5 sets forth the procedures that must be followed and the standards that 10 will be applied when a party seeks permission from the Court to file material under seal. 11 II. GOOD CAUSE STATEMENT 12 This action is likely to involve shareholder investment information, capitalization 13 tables, documents pertaining to valuations of the Defendant Genexa, Inc., documents 14 pertaining to the criminal case of Michael Sinel which were filed under seal in this court, 15 financial records, bank statements, trade secrets, business records and other valuable 16 research, development, commercial, financial, technical and proprietary information for 17 which special protection from public disclosure and from use for any purpose other than 18 prosecution of this action is warranted. Such confidential and proprietary materials and 19 information consist of, among other things, confidential business or financial 20 information, information regarding confidential business practices, or other confidential 21 research, development, or commercial information (including information implicating 22 privacy rights of third parties), information otherwise generally unavailable to the 23 public, or which may be privileged or otherwise protected from disclosure under state 24 or federal statutes, court rules, case decisions, or common law. Accordingly, to expedite 25 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 2 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 their handling at the end of the litigation, and to 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 confidential, 5 non-public manner, and there is good cause why it should not be part of the public 6 record of this case. 7 III. DEFINITIONS 8 A. 9 FMO-MAA Action: Michael Sinel v. Genexa Inc., et al. Case No. 2:22-cv-03961- 10 B. 11 of information or items under this Order. 12 C. 13 how it is generated, stored or maintained) or tangible things that qualify for 14 protection under Federal Rule of Civil Procedure 26(c), and as specified above 15 in the Good Cause Statement. 16 D. 17 their support staff). 18 E. 19 or items that it produces in disclosures or in responses to discovery as 20 “CONFIDENTIAL. 21 F. 22 of the medium or way it is generated, stored, or maintained 23 (including, among other things, testimony, transcripts, and tangible things), that 24 is produced or generated in disclosures or responses to discovery in this matter. 25 G. 26 pertinent to the litigation who has been retained by a Party or its counsel to serve 27 as an expert witness or as a consultant in this Action. 28 H. Challenging Party: A Party or Non-Party that challenges the designation “CONFIDENTIAL” Information or Items: Information (regardless of Counsel: Outside Counsel of Record and In-House Counsel (as well as Designating Party: A Party or Non-Party that designates information Disclosure or Discovery Material: All items or information, regardless Expert: A person with specialized knowledge or experience in a matter House Counsel: Attorneys who are employees of a party to this Action. 3 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 House Counsel does not include Outside Counsel of Record or any other 2 outside counsel. 3 I. 4 or other legal entity not named as a Party to this action. 5 J. 6 party to this Action but are retained to represent or advise a party to this Action 7 and have appeared in this Action on behalf of that party or are affiliated with a 8 law firm which has appeared on behalf of that party, and includes support staff. 9 K. Non-Party: Any natural person, partnership, corporation, association, Outside Counsel of Record: Attorneys who are not employees of a Party: Any party to this Action, including all of its officers, 10 directors, employees, consultants, retained experts, and 11 Outside Counsel of Record (and their support staffs). 12 L. 13 Discovery Material in this Action. 14 M. 15 support services (e.g., photocopying, videotaping, translating, preparing exhibits 16 or demonstrations, and organizing, storing, or retrieving data in any form or 17 medium) and their employees and subcontractors. 18 N. 19 designated as “CONFIDENTIAL.” 20 O. 21 Material from a Producing Party. 22 IV. SCOPE 23 The protections conferred by this Stipulation and Order cover not only Protected Producing Party: A Party or Non-Party that produces Disclosure or Professional Vendors: Persons or entities that provide litigation Protected Material: Any Disclosure or Discovery Material that is Receiving Party: A Party that receives Disclosure or Discovery 24 Material (as defined above), but also (1) any information copied or extracted from 25 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 26 Material; and (3) any testimony, conversations, or presentations by Parties or their 27 Counsel that might reveal Protected Material. 28 Any use of Protected Material at trial shall be governed by the orders of the trial 4 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 judge. This Order does not govern the use of Protected Material at trial. 2 V. DURATION 3 Even after final disposition of this litigation, the confidentiality obligations 4 imposed by this Order shall remain in effect until a Designating Party agrees otherwise 5 in writing or a court order otherwise directs. Final disposition shall be deemed to be the 6 later of (1) dismissal of all claims and defenses in this Action, with or without prejudice; 7 and (2) final judgment herein after the completion and exhaustion of all appeals, 8 rehearings, remands, trials, or reviews of this Action, including the time limits for filing 9 any motions or applications for extension of time pursuant to applicable law. 10 VI. DESIGNATING PROTECTED MATERIAL 11 A. Exercise of Restraint and Care in Designating Material for Protection. 12 1. Each Party or Nonparty that designates information or items for 13 protection under this Order must take care to limit any such designation 14 to specific material that qualifies under the appropriate standards. The 15 Designating Party must designate for protection only those parts of 16 material, documents, items, or communications that qualify so that other 17 portions of the material, documents, items, or communications for which 18 protection is not warranted are not swept unjustifiably within the ambit 19 of this Order. 20 2. Mass, indiscriminate, or routinized designations are prohibited. 21 Designations that are shown to be clearly unjustified or that have been 22 made for an improper purpose (e.g., to unnecessarily encumber the case 23 development process or to impose unnecessary expenses and burdens on 24 other parties) may expose the Designating Party to sanctions. 25 3. If it comes to a Designating Party’s attention that information or items 26 that it designated for protection do not qualify for protection, that 27 Designating Party must promptly notify all other Parties that it is 28 withdrawing the inapplicable designation. 5 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 B. Manner and Timing of Designations. 2 1. Except as otherwise provided in this Order (see, e.g., Section B(2)(b) 3 below), or as otherwise stipulated or ordered, Disclosure or Discovery 4 Material that qualifies for protection under this Order must be clearly so 5 designated before the material is disclosed or produced. 6 2. Designation in conformity with this Order requires the following: 7 a. For information in documentary form (e.g., paper or electronic 8 documents, but excluding transcripts of depositions or other pretrial or 9 trial proceedings), that the Producing Party affix at a minimum, the legend 10 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each 11 page that contains protected material. If only a portion or portions of the 12 material on a page qualifies for protection, the Producing Party also must 13 clearly identify the protected portion(s) (e.g., by making appropriate 14 markings in the margins). 15 b. A Party or Nonparty that makes original documents available for 16 inspection need not designate them for protection until after the inspecting 17 Party has indicated which documents it would like copied and produced. 18 During the inspection and before the designation, all of the material made 19 available for inspection shall be deemed “CONFIDENTIAL.” After the 20 inspecting Party has identified the documents it wants copied and 21 produced, the Producing Party must determine which documents, or 22 portions thereof, qualify for protection under this Order. Then, before 23 producing the specified documents, the Producing Party must affix the 24 “CONFIDENTIAL legend” to each page that contains Protected Material. 25 If only a portion or portions of the material on a page qualifies for 26 protection, the Producing Party also must clearly identify the protected 27 portion(s) (e.g., by making appropriate markings in the margins). 28 c. For testimony given in depositions, that the Designating Party identify the 6 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 Disclosure or Discovery Material on the record, before the close of the 2 deposition, all protected testimony. 3 d. For information produced in form other than document and for any other 4 tangible items, that the Producing Party affix in a prominent place on the 5 exterior of the container or containers in which the information is stored 6 the legend “CONFIDENTIAL.” If only a portion or portions of the 7 information warrants protection, the Producing Party, to the extent 8 practicable, shall identify the protected portion(s). 9 C. Inadvertent Failure to Designate. 10 1. If timely corrected, an inadvertent failure to designate qualified 11 information or items does not, standing alone, waive the Designating Party’s right 12 to secure protection under this Order for such material. Upon timely correction 13 of a designation, the Receiving Party must make reasonable efforts to assure that 14 the material is treated in accordance with the provisions of this Stipulated 15 Protective Order. 16 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 A. Timing of Challenges. 18 1. Any party or Non-Party may challenge a designation of confidentiality at 19 any time that is consistent with the Court’s Scheduling Order. 20 B. 21 Meet and Confer. 1. The Challenging Party shall initiate the dispute resolution process 22 which shall comply with Local Rule 37.1 et seq., and with Section 23 4 of Judge Audero’s Procedures (“Mandatory Telephonic 24 Conference for Discovery Disputes”). 1 25 C. The burden of persuasion in any such challenge proceeding shall be on the 26 27 28 1 Judge Audero’s Procedures are available at https://www.cacd.uscourts.gov/honorable-maria-audero. 7 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 Designating Party. Frivolous challenges, and those made for an improper 2 purpose (e.g., to harass or impose unnecessary expenses and burdens on 3 other parties) may expose the Challenging Party to sanctions. Unless the 4 Designating Party has waived or withdrawn the confidentiality 5 designation, all parties shall continue to afford the material in question the 6 level of protection to which it is entitled under the Producing Party’s 7 designation until the Court rules on the challenge. 8 VIII. ACCESS TO AND USE OF PROTECTED MATERIALS 9 A. Basic Principles. 10 1. A Receiving Party may use Protected Material that is disclosed or 11 produced by another Party or by a Non-Party in connection with this Action only for 12 prosecuting, defending, or attempting to settle this Action. Such Protected Material may 13 be disclosed only to the categories of persons and under the conditions described in this 14 Order. When the Action has been terminated, a Receiving Party must comply with the 15 provisions of Section XIV below. 16 2. Protected Material must be stored and maintained by a Receiving Party at 17 a location and in a secure manner that ensures that access is limited to the persons 18 authorized under this Order. 19 B. Disclosure of “CONFIDENTIAL” Information or Items. 20 1. Unless otherwise ordered by the Court or permitted in writing by the 21 Designating Party, a Receiving Party may disclose any information or item designated 22 “CONFIDENTIAL” only to: 23 a. The Receiving Party’s Outside Counsel of Record in this Action, as well 24 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 25 disclose the information for this Action; 26 b. The officers, directors, and employees (including House Counsel) of the 27 Receiving Party to whom disclosure is reasonably necessary for this Action; 28 c. Experts (as defined in this Order) of the Receiving Party to whom 8 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 disclosure is reasonably necessary for this Action and who have signed the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 d. The Court and its personnel; 4 e. Court reporters and their staff; 5 f. Professional jury or trial consultants, mock jurors, and Professional 6 Vendors to whom disclosure is reasonably necessary or this Action and who have signed 7 the “Acknowledgment and Agreement to be Bound” attached as Exhibit A hereto; 8 g. The author or recipient of a document containing the information or a 9 custodian or other person who otherwise possessed or knew the information; 10 h. During their depositions, witnesses, and attorneys for witnesses, in the 11 Action to whom disclosure is reasonably necessary provided: (i) the deposing party 12 requests that the witness sign the “Acknowledgment and Agreement to Be Bound;” and 13 (ii) they will not be permitted to keep any confidential information unless they sign the 14 “Acknowledgment and Agreement to Be Bound,” unless otherwise agreed by the 15 Designating Party or ordered by the Court. Pages of transcribed deposition testimony 16 or exhibits to depositions that reveal Protected Material may be separately bound by the 17 court reporter and may not be disclosed to anyone except as permitted under this 18 Stipulated Protective Order; and 19 i. Any mediator or settlement officer, and their supporting personnel, 20 mutually agreed upon by any of the parties engaged in settlement discussions. 21 IX. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 22 IN OTHER LITIGATION 23 A. If a Party is served with a subpoena or a court order issued in other 24 litigation that compels disclosure of any information or items designated in this Action 25 as “CONFIDENTIAL,” that Party must: 26 1. 27 28 Promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; 2. Promptly notify in writing the party who caused the subpoena or order to 9 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 issue in the other litigation that some or all of the material covered by the 2 subpoena or order is subject to this Protective Order. Such notification 3 shall include a copy of this Stipulated Protective Order; and 4 3. 5 6 Cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. B. If the Designating Party timely seeks a protective order, the Party served 7 with the subpoena or court order shall not produce any information designated in this 8 action as “CONFIDENTIAL” before a determination by the Court from which the 9 subpoena or order issued, unless the Party has obtained the Designating Party’s 10 permission. The Designating Party shall bear the burden and expense of seeking 11 protection in that court of its confidential material and nothing in these provisions 12 should be construed as authorizing or encouraging a Receiving Party in this Action to 13 disobey a lawful directive from another court. 14 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 15 PRODUCED IN THIS LITIGATION 16 A. The terms of this Order are applicable to information 17 produced by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 18 information produced by Non-Parties in connection with this litigation is protected by 19 the remedies and relief provided by this Order. Nothing in these provisions should be 20 construed as prohibiting a Non-Party from seeking additional protections. 21 B. In the event that a Party is required, by a valid discovery request, to 22 produce a Non-Party’s confidential information in its possession, and the Party is 23 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 24 information, then the Party shall: 25 1. 26 that some or all of the information requested is subject to a confidentiality 27 agreement with a Non-Party; 28 2. Promptly notify in writing the Requesting Party and the Nonparty Promptly provide the Nonparty with a copy of the Stipulated 10 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 Protective Order in this Action, the relevant discovery request(s), and a 2 reasonably specific description of the information requested; and 3 3. 4 5 Make the information requested available for inspection by the Nonparty, if requested. C. If the Non-Party fails to seek a protective order from this Court within 6 14 days after receiving the notice and accompanying information, the Receiving Party 7 may produce the Non-Party’s confidential information responsive to the discovery 8 request. If the Non-Party timely seeks a protective order, the Receiving Party shall not 9 produce any information in its possession or control that is subject to the confidentiality 10 agreement with the Non-Party before a determination by the Court. Absent a court order 11 to the contrary, the Non-Party shall bear the burden and expense of seeking protection 12 in this court of its Protected Material. 13 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 14 A. If a Receiving Party learns that, by inadvertence or otherwise, it has 15 disclosed Protected Material to any person or in any circumstance not authorized under 16 this Stipulated Protective Order, the Receiving Party must immediately (1) notify in 17 writing the Designating Party of the unauthorized disclosures, (2) use its best efforts to 18 retrieve all unauthorized copies of the Protected Material, (3) inform the person or 19 persons to whom unauthorized disclosures were made of all the terms of this Order, and 20 (4) request such person or persons to execute the “Acknowledgment and Agreement to 21 be Bound” that is attached hereto as Exhibit A. 22 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 A. When a Producing Party gives notice to Receiving Parties that certain 25 inadvertently produced material is subject to a claim of privilege or other protection, 26 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 27 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 28 may be established in an e-discovery order that provides for production without prior 11 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 2 parties reach an agreement on the effect of disclosure of a communication or 3 information covered by the attorney-client privilege or work product protection, the 4 parties may incorporate their agreement in the Stipulated Protective Order submitted to 5 the Court. 6 XIII. MISCELLANEOUS 7 A. Right to Further Relief 8 1. Nothing in this Order abridges the right of any 9 person to seek its modification by the Court in the future. 10 B. Right to Assert Other Objections. 11 1. By stipulating to the entry of this Stipulated Protective Order, no Party 12 waives any right it otherwise would have to object to disclosing or 13 producing any information or item on any ground not addressed in this 14 Stipulated Protective Order. Similarly, no Party waives any right to object 15 on any ground to use in evidence of any of the material covered by this 16 Stipulated Protective Order. 17 C. Filing Protected Material. 18 1. A Party that seeks to file under seal any Protected Material must comply 19 with Local Rule 79-5. Protected Material may only be filed under seal 20 pursuant to a court order authorizing the sealing of the specific Protected 21 Material at issue. If a Party's request to file Protected Material under seal 22 is denied by the Court, then the Receiving Party may file the information 23 in the public record unless otherwise instructed by the Court. 24 XIV. FINAL DISPOSITION 25 A. After the final disposition of this Action, as defined in Section V, within 26 sixty (60) days of a written request by the Designating Party, each Receiving Party must 27 return all Protected Material to the Producing Party or destroy such material. As used 28 in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 12 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 summaries, and any other format reproducing or capturing any of the Protected 2 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 3 must submit a written certification to the Producing Party (and, if not the same person 4 or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by 5 category, where appropriate) all the Protected Material that was returned or destroyed 6 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 7 compilations, summaries or any other format reproducing or capturing any of the 8 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 9 archival copy of all pleadings; motion papers; trial, deposition, and hearing transcripts; 10 legal memoranda; correspondence; deposition and trial exhibits; expert reports; attorney 11 work product; and consultant and expert work product, even if such materials contain 12 Protected Material. Any such archival copies that contain or constitute Protected 13 Material remain subject to this Order as set forth in Section V. 14 B. Any violation of this Order may be punished by any and all appropriate 15 measures including, without limitation, contempt proceedings and/or monetary 16 sanctions. 17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 18 19 Dated: September 14, 2022 20 21 22 /s/ Robert S. Ross Robert S. Ross Attorneys for Plaintiff Michael Sinel and CounterDefendants Michael Sinel and MSSMD Investments, Inc. 23 24 25 26 27 28 Dated: September 15, 2022 Wendy M. Thomas Betty T. Huynh Justin Rhee Attorneys for Defendants and Counter-Claimants Genexa, Inc., Max Spielberg, and David Johnson 13 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 2 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 3 4 Dated: September 15, 2022 5 6 Maria A. Audero United States Magistrate Judge 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 14 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _________________________ [print or type full name], of 4 _________________________ __________________ [print or type full address], 5 declare under penalty of perjury that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States District Court for the 7 Central District of California on [DATE] in the case of Michael Sinel v. Genexa, Inc. 8 et al. Case No. 2:22-cv-03961-FMO-MAA.. I agree to comply with and to be bound 9 by all the terms of this Stipulated Protective Order and I understand and acknowledge 10 that failure to so comply could expose me to sanctions and punishment in the nature of 11 contempt. I solemnly promise that I will not disclose in any manner any information 12 or item that is subject to this Stipulated Protective Order to any person or entity except 13 in strict compliance with the provisions of this Stipulated Protective Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the 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 18 _________________________________________ [print or type full name] of 19 ________________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: _________________________________ 24 City and State Where Sworn and Signed: _________________________________ 25 Printed Name: _________________________________ 26 Signature: _________________________________ 27 28 15 STIPULATED PROTECTIVE ORDER 2:22-cv-03961-FMO-MAA

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