Patricia A. McConnell v. Lowes Home Centers, LLC et al

Filing 19


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1 2 3 4 5 6 7 8 Hunton & Williams LLP EMILY BURKHARDT VICENTE, SBN 263990 MATTHEW I. BOBB, SBN 253308 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 Telephone: 213 • 532 • 2000 Facsimile: 213 • 532 • 2020 Attorney for Defendant LOWE’S HOME CENTERS, LLC 9 Hunton & Williams LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12 PATRICIA MCCONNELL, PLAINTIFF, 13 14 V. 15 LOWE’S HOME CENTERS, LLC, AND DOES 1 TO 50, INCLUSIVE, 16 DEFENDANTS. 17 18 CASE NO. 5:17-cv-1356-JGB (SPx) Hon. Jesus G. Bernal [PROPOSED] STIPULATED PROTECTIVE ORDER [Discovery Matter: Referred to Magistrate Judge Sheri Pym] 19 20 21 22 1. A. PURPOSES AND LIMITATIONS 23 Discovery in this action is likely to involve production of confidential, 24 proprietary, or private information for which special protection from public disclosure 25 and from use for any purpose other than prosecuting this litigation may be warranted. 26 Accordingly, the parties hereby stipulate to and petition the Court to enter the 27 following Stipulated Protective Order. The parties acknowledge that this Order does 28 not confer blanket protections on all disclosures or responses to discovery and that 1 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 the protection it affords from public disclosure and use extends only to the limited 2 information or items that are entitled to confidential treatment under the applicable 3 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 4 that this Stipulated Protective Order does not entitle them to file confidential 5 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 6 followed and the standards that will be applied when a party seeks permission from 7 the court to file material under seal. 8 B. GOOD CAUSE STATEMENT 9 The parties submit that good cause exists for the issuance of this Protective Hunton & Williams LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 10 11 Order for the following reasons: (i) Discovery obtained in the above-captioned action may involve 12 disclosure of non-public, confidential, proprietary, commercially sensitive and/or 13 trade secret information. Disclosure of this information to persons who are not 14 entitled to it carries the danger of compromising the competitive business interests 15 of Defendant, and also risks invasion of legitimate personal privacy interests of 16 Plaintiff and non-parties; 17 (ii) Defendant anticipates that it may need to produce material that contains 18 proprietary information concerning its business practices and procedures for the 19 operation of its stores that may be of value to a competitor or may cause harm to its 20 legitimate business interests in the marketplace; 21 (iii) Defendant further anticipates that it may need to produce non-public 22 information concerning Plaintiff or non-parties that is personal in nature and/or 23 protected by the right of privacy; 24 (iv) The issuance of this Protective Order will allow for efficiency in the 25 discovery process and provide a mechanism by which discovery of relevant 26 confidential information may be obtained in a manner that protects against risk of 27 disclosure of such information to persons not entitled to such information; and 28 2 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 (v) The issuance of this Protective Order will protect the parties’ interests 2 by providing the parties recourse in this Court in the event that a party or non-party 3 improperly handles non-public, confidential, proprietary, commercially sensitive 4 and/or trade secret information that the parties have had to exchange in the course of 5 discovery propounded and depositions taken in this action. 6 (vi) Accordingly, to expedite the flow of information, to facilitate the 7 prompt resolution of disputes over confidentiality of discovery materials, to 8 adequately protect information the parties are entitled to keep confidential, to ensure 9 that the parties are permitted reasonable necessary uses of such material in Hunton & Williams LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 10 preparation for and in the conduct of trial, to address their handling at the end of the 11 litigation, and serve the ends of justice, a protective order for such information is 12 justified in this matter. It is the intent of the parties that information will not be 13 designated as confidential for tactical reasons and that nothing be so designated 14 without a good faith belief that it has been maintained in a confidential, non-public 15 manner, and there is good cause why it should not be part of the public record of 16 this case. 17 18 19 20 21 22 2. DEFINITIONS 2.1. Action: This pending federal law suit, Patricia McConnell v. Lowe’s Home Centers, LLC, Case No.: 5:17-cv-1356-JGB (SPx). 2.2. Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 23 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 24 how it is generated, stored or maintained) or tangible things that qualify for protection 25 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 26 Cause Statement. 27 28 2.4. Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 3 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 2.5. Designating Party: a Party or Non-Party that designates information or 2 items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 2.6. Disclosure or Discovery Material: all items or information, regardless of 5 the medium or manner in which it is generated, stored, or maintained (including, 6 among other things, testimony, transcripts, and tangible things), that are produced or 7 generated in disclosures or responses to discovery in this matter. 8 2.7. Expert: a person with specialized knowledge or experience in a matter 9 pertinent to the litigation who has been retained by a Party or its counsel to serve as Hunton & Williams LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 10 an expert witness or as a consultant in this Action. 11 2.8. House Counsel: attorneys who are employees of a party to this Action. 12 House Counsel does not include Outside Counsel of Record or any other outside 13 counsel. 14 15 2.9. Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 16 2.10. Outside Counsel of Record: attorneys who are not employees of a party 17 to this Action but are retained to represent or advise a party to this Action and have 18 appeared in this Action on behalf of that party or are affiliated with a law firm which 19 has appeared on behalf of that party, and includes support staff. 20 2.11. Party: any party to this Action, including all of its officers, directors, 21 employees, consultants, retained experts, and Outside Counsel of Record (and their 22 support staffs). 23 24 2.12. Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 25 2.13. Professional Vendors: persons or entities that provide litigation support 26 services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 demonstrations, and organizing, storing, or retrieving data in any form or medium) 28 and their employees and subcontractors. 4 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 2 2.14. Protected Material: designated as “CONFIDENTIAL.” 3 4 any Disclosure or Discovery Material that is 2.15. Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party. 5 6 3. SCOPE Protected Material (as defined above), but also (1) any information copied or 9 extracted from Protected Material; (2) all copies, excerpts, summaries, or 10 Hunton & Williams LLP The protections conferred by this Stipulation and Order cover not only 8 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 7 compilations of Protected Material; and (3) any testimony, conversations, or 11 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 12 13 trial judge. This Order does not govern the use of Protected Material at trial. 14 15 4. DURATION 16 Even after final disposition of this litigation, the confidentiality obligations 17 imposed by this Order shall remain in effect until a Designating Party agrees 18 otherwise in writing or a court order otherwise directs. Final disposition shall be 19 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 20 or without prejudice; and (2) final judgment herein after the completion and 21 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 22 including the time limits for filing any motions or applications for extension of time 23 pursuant to applicable law. 24 25 5. DESIGNATING PROTECTED MATERIAL 26 5.1. Exercise of Restraint and Care in Designating Material for Protection. 27 Each Party or Non-Party that designates information or items for protection 28 under this Order must take care to limit any such designation to specific material that 5 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 qualifies under the appropriate standards. The Designating Party must designate for 2 protection only those parts of material, documents, items, or oral or written 3 communications that qualify so that other portions of the material, documents, items, 4 or communications for which protection is not warranted are not swept unjustifiably 5 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 (e.g., to unnecessarily encumber the case development process or to impose 9 unnecessary expenses and burdens on other parties) may expose the Designating Party Hunton & Williams LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 10 to sanctions. 11 If it comes to a Designating Party’s attention that information or items that it 12 designated for protection do not qualify for protection, that Designating Party must 13 promptly notify all other Parties that it is withdrawing the inapplicable designation. 14 5.2. Manner and Timing of Designations. Except as otherwise provided in 15 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 16 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 17 under this Order must be clearly so designated before the material is disclosed or 18 produced. 19 20 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 21 documents, but excluding transcripts of depositions or other pretrial or trial 22 proceedings), that the Producing Party affix at a minimum, the legend 23 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 24 contains protected material. If only a portion or portions of the material on a page 25 qualifies for protection, the Producing Party also must clearly identify the protected 26 portion(s) (e.g., by making appropriate markings in the margins). 27 A Party or Non-Party that makes original documents available for inspection 28 need not designate them for protection until after the inspecting Party has indicated 6 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 which documents it would like copied and produced. During the inspection and before 2 the designation, all of the material made available for inspection shall be deemed 3 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 4 copied and produced, the Producing Party must determine which documents, or 5 portions thereof, qualify for protection under this Order. Then, before producing the 6 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 7 to each page that contains Protected Material. If only a portion or portions of the 8 material on a page qualifies for protection, the Producing Party also must clearly 9 identify the protected portion(s) (e.g., by making appropriate markings in the Hunton & Williams LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 10 11 margins). (b) for testimony given in depositions that the Designating Party 12 identify the Disclosure or Discovery Material on the record, before the close of the 13 deposition all protected testimony. Any Party may also designate testimony that is 14 entitled to protection by notifying all Parties in writing within twenty (20) days of 15 receipt of the transcript, of the specific pages and lines of the transcript that should be 16 treated as “Confidential” thereafter. Each Party shall attach a copy of such written 17 notice or notices to the face of the transcript and each copy thereof in its possession, 18 custody, or control. Unless otherwise indicated, all deposition transcripts shall be 19 treated as “Confidential” for a period of twenty (20) days after the receipt of the 20 transcript. This preliminary treatment, however, shall not limit a deponent’s right to 21 review the transcript of his or her deposition. This preliminary treatment shall not 22 limit a Party's use of any deposition transcript or exhibits, which have not previously 23 been expressly designated for protection under this order, from using such transcript 24 or exhibits in filings concerning any motion or at any subsequent deposition, 25 settlement conference, mediation or other proceeding related to the Action. 26 (c) for information produced in some form other than documentary and 27 for any other tangible items, that the Producing Party affix in a prominent place on 28 the exterior of the container or containers in which the information is stored the legend 7 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 “CONFIDENTIAL.” If only a portion or portions of the information warrants 2 protection, the Producing Party, to the extent practicable, shall identify the protected 3 portion(s). 4 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 5 failure to designate qualified information or items does not, standing alone, waive the 6 Designating Party’s right to secure protection under this Order for such material. 7 Upon timely correction of a designation, the Receiving Party must make reasonable 8 efforts to assure that the material is treated in accordance with the provisions of this 9 Order. Hunton & Williams LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 10 11 6. 12 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1. Timing of Challenges. Any Party or Non-Party may challenge a 13 designation of confidentiality at any time that is consistent with the Court’s 14 Scheduling Order. 15 16 6.2. Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37.1 et seq. 17 6.3. The burden of persuasion in any such challenge proceeding shall be on 18 the Designating Party. Frivolous challenges, and those made for an improper purpose 19 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 20 expose the Challenging Party to sanctions. Unless the Designating Party has waived 21 or withdrawn the confidentiality designation, all parties shall continue to afford the 22 material in question the level of protection to which it is entitled under the Producing 23 Party’s designation until the Court rules on the challenge. 24 25 7. ACCESS TO AND USE OF PROTECTED MATERIAL 26 7.1. Basic Principles. A Receiving Party may use Protected Material that is 27 disclosed or produced by another Party or by a Non-Party in connection with this 28 Action only for prosecuting, defending, or attempting to settle this Action. Such 8 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 Protected Material may be disclosed only to the categories of persons and under the 2 conditions described in this Order. When the Action has been terminated, a Receiving 3 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 4 Protected Material must be stored and maintained by a Receiving Party at a 5 location and in a secure manner that ensures that access is limited to the persons 6 authorized under this Order. 7 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless 8 otherwise ordered by the court or permitted in writing by the Designating Party, a 9 Receiving Party may disclose Hunton & Williams LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 10 (a) information or item designated “CONFIDENTIAL” only to: 11 any the Receiving Party’s Outside Counsel of Record in this Action, as 12 well as employees of said Outside Counsel of Record to whom it is reasonably 13 necessary to disclose the information for this Action; 14 15 16 (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 17 disclosure is reasonably necessary for this Action and who have signed the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (d) the court and its personnel; 20 (e) court reporters and their staff; 21 (f) professional jury or trial consultants, mock jurors, and Professional 22 Vendors to whom disclosure is reasonably necessary for this Action and who have 23 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 25 26 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; (h) during their depositions, witnesses, and attorneys for witnesses, in 27 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 28 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they 9 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 will not be permitted to keep any confidential information unless they sign the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 3 agreed by the Designating Party or ordered by the court. Pages of transcribed 4 deposition testimony or exhibits to depositions that reveal Protected Material may be 5 separately bound by the court reporter and may not be disclosed to anyone except as 6 permitted under this Stipulated Protective Order; and (i) 7 8 any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 9 Hunton & Williams LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 10 8. 11 IN OTHER LITIGATION 12 PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED If a Party is served with a subpoena or a court order issued in other litigation 13 that compels disclosure of any information or items designated in this Action as 14 “CONFIDENTIAL,” while such materials remain under the protection of this order, that Party must: 15 16 17 18 19 20 21 22 23 24 25 26 27 28 (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 to issue in the other litigation that some or all of the material covered by the subpoena or order is subject to this Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with the subpoena or court order shall not produce any information designated in this action as “CONFIDENTIAL” before a determination by the court from which the subpoena or order issued, unless the Party has obtained the Designating Party’s permission. The Designating Party shall bear the burden and expense of seeking 10 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 protection in that court of its confidential material and nothing in these provisions 2 should be construed as authorizing or encouraging a Receiving Party in this Action to 3 disobey a lawful directive from another court. 4 5 9. 6 PRODUCED IN THIS LITIGATION 7 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE (a) The terms of this Order are applicable to information produced by produced by Non-Parties in connection with this litigation is protected by the 10 Hunton & Williams LLP a Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 9 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 8 remedies and relief provided by this Order. Nothing in these provisions should be 11 construed as prohibiting a Non-Party from seeking additional protections. 12 (b) In the event that a Party is required, by a valid discovery request, 13 to produce a Non-Party’s confidential information in its possession, and the Party is 14 subject to an agreement with the Non-Party not to produce the Non-Party’s 15 confidential information, then the Party shall: (1) 16 promptly notify in writing the Requesting Party and the Non- 17 Party that some or all of the information requested is subject to a confidentiality 18 agreement with a Non-Party; (2) 19 promptly provide the Non-Party with a copy of the 20 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 21 reasonably specific description of the information requested; and (3) 22 make the information requested available for inspection by 23 the Non-Party, if requested. 24 (c) If the Non-Party fails to seek a protective order from this court 25 within 14 days of receiving the notice and accompanying information, the Receiving 26 Party may produce the Non-Party’s confidential information responsive to the 27 discovery request. If the Non-Party timely seeks a protective order, the Receiving 28 Party shall not produce any information in its possession or control that is subject to 11 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 the confidentiality agreement with the Non-Party before a determination by the court. 2 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 3 of seeking protection in this court of its Protected Material. 4 5 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 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 Hunton & Williams LLP If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 7 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 11 persons to whom unauthorized disclosures were made of all the terms of this Order, 12 and (d) request such person or persons to execute the “Acknowledgment and 13 Agreement to Be Bound” that is attached hereto as Exhibit A. 14 15 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 PROTECTED MATERIAL 17 When a Producing Party gives notice to Receiving Parties that certain 18 inadvertently produced material is subject to a claim of privilege or other protection, 19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 21 may be established in an e-discovery order that provides for production without prior 22 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 23 parties reach an agreement on the effect of disclosure of a communication or 24 information covered by the attorney-client privilege or work product protection, the 25 parties may incorporate their agreement in the stipulated protective order submitted 26 to the court. 27 28 12 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 2 3 12. 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. 4 12.2. Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in this 7 Stipulated Protective Order. Similarly, no Party waives any right to object on any 8 ground to use in evidence of any of the material covered by this Protective Order. Hunton & Williams LLP 12.3. Filing Protected Material. A Party that seeks to file under seal any 10 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 9 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 11 only be filed under seal pursuant to a court order authorizing the sealing of the specific 12 Protected Material at issue. If a Party’s request to file Protected Material under seal 13 is denied by the court, then the Receiving Party may file the information in the public 14 record unless otherwise instructed by the court. 15 16 13. FINAL DISPOSITION 17 After the final disposition of this Action, as defined in paragraph 4, within 60 18 days of a written request by the Designating Party, each Receiving Party must return 19 all Protected Material to the Producing Party or destroy such material. As used in this 20 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 21 summaries, and any other format reproducing or capturing any of the Protected 22 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 23 must submit a written certification to the Producing Party (and, if not the same person 24 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 25 category, where appropriate) all the Protected Material that was returned or destroyed 26 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 27 compilations, summaries or any other format reproducing or capturing any of the 28 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 13 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 archival copy of all pleadings, motion papers, trial, deposition, and hearing 2 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 3 reports, attorney work product, and consultant and expert work product, even if such 4 materials contain Protected Material. Any such archival copies that contain or 5 constitute Protected Material remain subject to this Protective Order as set forth in 6 Section 4 (DURATION). 7 14. Any violation of this Order may be punished by any and all appropriate 8 measures including, without limitation, contempt proceedings and/or monetary 9 sanctions. Hunton & Williams LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 10 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 11 DATED February 7, 2018 12 LAW OFFICES OF LARRY R. HODDICK, P.C. Attorneys for Plaintiff 13 14 15 By: /s/ Larry R. Hoddick LARRY R HODDICK Patricia McConnell 16 17 18 19 20 21 22 23 CONSUMER LAW OFFICE OF ROBERT STEMPLER, APC DATED February 7, 2018 HUNTON & WILLIAMS LLP By: /s/ Matthew I. Bobb___________ Emily Burkhardt Vicente Matthew I. Bobb Attorneys for Defendant Lowe’s Home Centers, LLC Attestation Pursuant to Local Rule 5-4.3.4(a)(2)(i) 24 25 26 27 28 I, Matthew I. Bobb, attest that all other signatories listed, and on whose behalf this filing is submitted, concur in the filing’s content and have authorized the filing. By: /s/Matthew I. Bobb Matthew I. Bobb 14 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 DATED February 9, 2018 3 4 5 6 Honorable Sheri Pym UNITED STATES MAGISTRATE JUDGE 7 8 9 Hunton & Williams LLP 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, 4 ________________________ [print or type full name], of that I have read in its entirety and understand the Stipulated Protective Order that was 7 issued by the United States District Court for the Central District of California on 8 [____](date) in the case of Patricia McConnell v. Lowe’s Home Centers, LLC, Case 9 No.: 5:17-CV-1356-JGB-SPx). I agree to comply with and to be bound by all the 10 Hunton & Williams LLP ____________________ [print or type full address], declare under penalty of perjury 6 550 South Hope Street, Suite 2000 Los Angeles, California 90071-2627 5 terms of this Stipulated Protective Order and I understand and acknowledge that 11 failure to so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any information 13 or item that is subject to this Stipulated Protective Order to any person or entity except 14 in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint ____________________________ [print 19 or type full name] of _________________________________ [print or type full 20 address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 Date: 24 City and State where sworn and signed: 25 26 27 Printed Name: Signature: 28 16 [PROPOSED] STIPULATED PROTECTIVE ORDER

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