Ahmad Karimkhani v. Real Time Resolutions, Inc. et al

Filing 35

ORDER APPROVING STIPULATED PROTECTIVE ORDER by Magistrate Judge Kenly Kiya Kato re Stipulation for Protective Order 31 . (dts)

1 Abraham J. Colman (SBN 146933)

Email: [e-mail]

2 Raffi Kassabian (SBN 260358)

Email: [e-mail]

3 Sevana Zadourian (SBN 315037)

Email: szadourian@reedsmith

4 REED SMITH LLP

355 South Grand Avenue, Suite 2900

5 Los Angeles, CA 90071-1514

Telephone: [phone]
[phone]

6 Facsimile:

7 Attorneys for Defendant Real Time

Resolutions, Inc.

8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10

EASTERN DIVISION

11

AHMAD KARIMKHANI and MONIREH Case No.: 5:18-cv-00730-JGB-KK

12 KARIMKHANI, individuals,
13
14

Plaintiffs,
vs.

15 REAL TIME RESOLUTIONS, INC., a

Hon. Jesus G. Bernal
STIPULATED PROTECTIVE
ORDER

Texas Corporation; and PROBER &

16 RAPHAEL, a law corporation in
17
18

California,

Defendants.

19
20
21

A. PURPOSES AND LIMITATIONS

22

Discovery in this action is likely to involve production of confidential,

23 proprietary, or private information for which special protection from public
24 disclosure and from use for any purpose other than prosecuting this litigation may be
25 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter
26 the following Stipulated Protective Order. The parties acknowledge that this Order
27 does not confer blanket protections on all disclosures or responses to discovery
28 and that the protection it affords from public disclosure and use extends only to the
STIPULATED PROTECTIVE ORDER

1 limited information or items that are entitled to confidential treatment under the
2 applicable legal principles.
3

B. GOOD CAUSE STATEMENT

4

This action is likely to involve confidential financial and proprietary

5 information relating to the confidential financial information and business practices
6 and policies of Defendant Real Time Resolutions, Inc. (“Real Time”) and confidential
7 information relating to Plaintiffs Ahmad and Monireh Karimkhani for which special
8 protection from public disclosure and from use for any purpose other than the
9 litigation of this action is warranted. Such confidential and proprietary materials and

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 information consist of, among other things, confidential financial information,
11 information regarding confidential business practices, or other confidential research,
12 development, or commercial information, information otherwise generally unavailable
13 to the public, or which may be privileged or otherwise protected from disclosure under
14 state or federal statutes, court rules, case decisions, or common law. Accordingly, to
15 expedite the flow of information, to facilitate the prompt resolution of disputes over
16 confidentiality of discovery materials, to adequately protect information the parties are
17 entitled to keep confidential, to ensure that the parties are permitted reasonable
18 necessary uses of such material in preparation for and in the conduct of trial, to
19 address their handling at the end of the litigation, and serve the ends of justice, a
20 protective order for such information is justified in this matter. It is the intent of the
21 parties that information will not be designated as confidential for tactical reasons and
22 that nothing be so designated without a good faith belief that it has been maintained in
23 a confidential, non-public manner, and there is good cause why it should not be part of
24 the public record of this case.
25
26
27

C.

ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
SEAL

The parties further acknowledge, as set forth in Section 12.3, below, that this

28 Stipulated Protective Order does not entitle them to file confidential information under
STIPULATED PROTECTIVE ORDER
-2-

1 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
2 standards that will be applied when a party seeks permission from the court to file
3 material under seal.
4

There is a strong presumption that the public has a right of access to judicial

5 proceedings and records in civil cases. In connection with non-dispositive motions,
6 good cause must be shown to support a filing under seal. See Kamakana v. City and
7 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
8 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,
9 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 cause showing), and a specific showing of good cause or compelling reasons with
11 proper evidentiary support and legal justification, must be made with respect to
12 Protected Material that a party seeks to file under seal. The parties’ mere designation
13 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the
14 submission of competent evidence by declaration, establishing that the material sought
15 to be filed under seal qualifies as confidential, privileged, or otherwise protectable—
16 constitute good cause.
17

Further, if a party requests sealing related to a dispositive motion or trial, then

18 compelling reasons, not only good cause, for the sealing must be shown, and the relief
19 sought shall be narrowly tailored to serve the specific interest to be protected. See
20 Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each
21 item or type of information, document, or thing sought to be filed or introduced under
22 seal in connection with a dispositive motion or trial, the party seeking protection must
23 articulate compelling reasons, supported by specific facts and legal justification, for
24 the requested sealing order. Again, competent evidence supporting the application to
25 file documents under seal must be provided by declaration.
26

Any document that is not confidential, privileged, or otherwise protectable in its

27 entirety will not be filed under seal if the confidential portions can be redacted. If
28 documents can be redacted, then a redacted version for public viewing, omitting only
STIPULATED PROTECTIVE ORDER
-3-

1 the confidential, privileged, or otherwise protectable portions of the document, shall
2 be filed. Any application that seeks to file documents under seal in their entirety
3 should include an explanation of why redaction is not feasible.
4

DEFINITIONS

5

2.1

Action: the present lawsuit, entitled Ahmad Karimkhani and Monireh

6 Karimkhani v. Real Time Resolutions, Inc., et al., Case No. 5:18-cv-00730-JGB-KK.
7

2.2

Challenging Party: a Party or Non-Party that challenges the designation

8 of information or items under this Order.
9

2.3

“CONFIDENTIAL” Information or Items: information (regardless of

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 how it is generated, stored or maintained) or tangible things that qualify for protection
11 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
12 Cause Statement.
13

2.4

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

14 support staff).
15
16 items

2.5

Designating Party: a Party or Non-Party that designates information or

that it produces in disclosures or in responses to discovery as

17 “CONFIDENTIAL.”
18

2.6

Disclosure or Discovery Material: all items or information, regardless of

19 the medium or manner in which it is generated, stored, or maintained (including,
20 among other things, testimony, transcripts, and tangible things), that are produced or
21 generated in disclosures or responses to discovery in this matter.
22

2.7

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

23 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
24 expert witness or as a consultant in this Action.
25

2.8

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

26 House Counsel does not include Outside Counsel of Record or any other outside
27 counsel.
28
STIPULATED PROTECTIVE ORDER
-4-

1

2.9

Non-Party: any natural person, partnership, corporation, association, or

2 other legal entity not named as a Party to this action.
3

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

4 to this Action but are retained to represent or advise a party to this Action and have
5 appeared in this Action on behalf of that party or are affiliated with a law firm which
6 has appeared on behalf of that party, and includes support staff.
7

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

8 employees, consultants, retained experts, and Outside Counsel of Record (and their
9 support staffs).

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10

2.12 Producing Party: a Party or Non-Party that produces Disclosure or

11 Discovery Material in this Action.
12

2.13 Professional Vendors: persons or entities that provide litigation support

13 services

(e.g., photocopying, videotaping, translating, preparing exhibits or

14 demonstrations, and organizing, storing, or retrieving data in any form or medium)
15 and their employees and subcontractors.
16

2.14 Protected Material: any Disclosure or Discovery Material that is

17 designated as “CONFIDENTIAL.”
18

2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

19 from a Producing Party.
20

SCOPE

21

The protections conferred by this Stipulation and Order cover not only

22 Protected Material (as defined above), but also (1) any information copied or extracted
23 from Protected Material; (2) all copies, excerpts, summaries, or compilations of
24 Protected Material; and (3) any testimony, conversations, or presentations by Parties
25 or their Counsel that might reveal Protected Material.
26

Any use of Protected Material at trial shall be governed by the orders of the trial

27 judge. This Order does not govern the use of Protected Material at trial.
28
STIPULATED PROTECTIVE ORDER
-5-

1

DURATION

2

Even after final disposition of this litigation, the confidentiality obligations

3 imposed by this Order shall remain in effect until a Designating Party agrees
4 otherwise in writing or a court order otherwise directs.

Final disposition shall be

5 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
6 or without prejudice; and (2) final judgment herein after the completion and
7 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
8 including the time limits for filing any motions or applications for extension of time
9 pursuant to applicable law.

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10

DESIGNATING PROTECTED MATERIAL

11

5.1

Exercise of Restraint and Care in Designating Material for Protection.

12 Each Party or Non-Party that designates information or items for protection under this
13 Order must take care to limit any such designation to specific material that qualifies
14 under the appropriate standards. The Designating Party must designate for protection
15 only those parts of material, documents, items, or oral or written communications that
16 qualify so

that

17 communications

other
for

portions

which

of

protection

the
is

material,
not

documents, items,

warranted

are

not

or

swept

18 unjustifiably within the ambit of this Order.
19

Mass, indiscriminate, or routinized designations are prohibited. Designations

20 that are shown to be clearly unjustified or that have been made for an improper
21 purpose (e.g., to unnecessarily encumber the case development process or to impose
22 unnecessary expenses and burdens on other parties) may expose the Designating Party
23 to sanctions.
24

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

25 designated for protection do not qualify for protection, that Designating Party must
26 promptly notify all other Parties that it is withdrawing the inapplicable designation.
27

5.2

Manner and Timing of Designations. Except as otherwise provided in

28 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
STIPULATED PROTECTIVE ORDER
-6-

1 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
2 under this Order must be clearly so designated before the material is disclosed or
3 produced.
4

Designation in conformity with this Order requires:
(a)

5

for information in documentary form (e.g., paper or electronic

6 documents, but excluding transcripts of depositions or other pretrial or trial
7 proceedings),

that the Producing Party affix at a minimum, the legend

8 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
9 contains protected material. If only a portion or portions of the material on a page

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 qualifies for protection, the Producing Party also must clearly identify the protected
11 portion(s) (e.g., by making appropriate markings in the margins).
12

A Party or Non-Party that makes original documents available for inspection

13 need not designate them for protection until after the inspecting Party has indicated
14 which documents it would like copied and produced. During the inspection and before
15 the designation, all of the material made available for inspection shall be deemed
16 “CONFIDENTIAL.” After

the

inspecting Party has identified the documents it

17 wants copied and produced, the Producing Party must determine which documents, or
18 portions thereof, qualify for protection under this Order. Then, before producing the
19 specified documents, the Producing Party must affix the “CONFIDENTIAL legend”
20 to each page that contains Protected Material. If only a portion or portions of the
21 material on a page qualifies for protection, the Producing Party also must clearly
22 identify the protected portion(s) (e.g., by making appropriate markings in the
23 margins).
24

(b)

for testimony given in depositions that the Designating Party

25 identify the Disclosure or Discovery Material on the record, before the close of the
26 deposition all protected testimony.
27

(c)

for information produced in some form other than documentary

28 and for any other tangible items, that the Producing Party affix in a prominent place
STIPULATED PROTECTIVE ORDER
-7-

1 on the exterior of the container or containers in which the information is stored the
2 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants
3 protection, the Producing Party, to the extent practicable, shall identify the protected
4 portion(s).
5

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

6 failure to designate qualified information or items does not, standing alone, waive the
7 Designating Party’s right to secure protection under this Order for such material.
8 Upon timely correction of a designation, the Receiving Party must make reasonable
9 efforts to assure that the material is treated in accordance with the provisions of this

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 Order.
11

CHALLENGING CONFIDENTIALITY DESIGNATIONS

12

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

6.2

Meet and Confer. The Challenging Party shall meet and confer with the

16 other party prior to challenging a designation of confidentiality.
17

6.3

Joint Stipulation. Any challenge submitted to the Court shall be via a

18 joint stipulation pursuant to Local Rule 37-2.
19

6.4

The burden of persuasion in any such challenge proceeding shall be on

20 the Designating Party. Frivolous challenges, and those made for an improper purpose
21 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
22 expose the Challenging Party to sanctions. Unless the Designating Party has waived
23 or withdrawn the confidentiality designation, all parties shall continue to afford the
24 material in question the level of protection to which it is entitled under the Producing
25 Party’s designation until the Court rules on the challenge.
26

ACCESS TO AND USE OF PROTECTED MATERIAL

27

7.1

Basic Principles. A Receiving Party may use Protected Material that is

28 disclosed or produced by another Party or by a Non-Party in connection with this
STIPULATED PROTECTIVE ORDER
-8-

1 Action only for prosecuting, defending, or attempting to settle this Action.

Such

2 Protected Material may be disclosed only to the categories of persons and under the
3 conditions described in this Order. When the Action has been terminated, a Receiving
4 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
5

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

6 location and in a secure manner that ensures that access is limited to the persons
7 authorized under this Order.
8

7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

9 otherwise ordered by the court or permitted in writing by the Designating Party, a

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 Receiving Party may disclose any information or item designated “CONFIDENTIAL”
11 only to:
12

(a)

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

13 well as employees of said Outside Counsel of Record to whom it is reasonably
14 necessary to disclose the information for this Action;
15

(b)

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

16 of the Receiving Party to whom disclosure is reasonably necessary for this Action;
17

(c)

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

18 disclosure is reasonably necessary for this Action and who have signed the
19 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
20

(d)

the court and its personnel;

21

(e)

court reporters and their staff;

22

(f)

professional jury or trial consultants, mock jurors, and Professional

23 Vendors to whom disclosure is reasonably necessary for this Action and who have
24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25

(g)

the author or recipient of a document containing the information or

26 a custodian or other person who otherwise possessed or knew the information;
27

(h)

during their depositions, witnesses, and attorneys for witnesses, in

28 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
STIPULATED PROTECTIVE ORDER
-9-

1 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
2 they will not be permitted to keep any confidential information unless they sign the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
4 agreed by the Designating Party or ordered by the court.

Pages of transcribed

5 deposition testimony or exhibits to depositions that reveal Protected Material may be
6 separately bound by the court reporter and may not be disclosed to anyone except as
7 permitted under this Stipulated Protective Order; and

(i)

8

any mediator or settlement officer, and their supporting personnel,

9 mutually agreed upon by any of the parties engaged in settlement discussions.

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

11

IN OTHER LITIGATION

12

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,” that Party must:

(a)

15

promptly notify in writing the Designating Party. Such notification

16 shall include a copy of the subpoena or court order;

(b)

17

promptly notify in writing the party who caused the subpoena or

18 order to issue in the other litigation that some or all of the material covered by the
19 subpoena or order is subject to this Protective Order. Such notification shall include a
20 copy of this Stipulated Protective Order; and

(c)

21

cooperate with respect to all reasonable procedures sought to be

22 pursued by the Designating Party whose Protected Material may be affected.
23

If the Designating Party timely seeks a protective order, the Party served with

24 the subpoena or court order shall not produce any information designated in this
25 action as “CONFIDENTIAL” before a determination by the court from which the
26 subpoena or order issued, unless the Party has obtained the Designating Party’s
27 permission.

The Designating Party shall bear the burden and expense of seeking

28 protection in that court of its confidential material and nothing in these provisions
STIPULATED PROTECTIVE ORDER
- 10 -

1 should be construed as authorizing or encouraging a Receiving Party in this Action to
2 disobey a lawful directive from another court.
3

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

4

PRODUCED IN THIS LITIGATION

5

(a)

The terms of this Order are applicable to information produced by

6 a Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
7 produced by Non-Parties in connection with this litigation is protected by the
8 remedies and relief provided by this Order. Nothing in these provisions should be
9 construed as prohibiting a Non-Party from seeking additional protections.

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10

(b)

In the event that a Party is required, by a valid discovery request,

11 to produce a Non-Party’s confidential information in its possession, and the Party is
12 subject to an agreement with the Non-Party not to produce the Non-Party’s
13 confidential information, then the Party shall:

(1)

14

promptly notify in writing the Requesting Party and the

15 Non-Party that some or all of the information requested is subject to a confidentiality
16 agreement with a Non-Party;

(2)

17

promptly provide the Non-Party with a copy of the

18 Stipulated Protective Order in this Action, the relevant discovery request(s), and a
19 reasonably specific description of the information requested; and

(3)

20

make the information requested available for inspection by

21 the Non-Party, if requested.
22

(c)

If the Non-Party fails to seek a protective order from this court

23 within 14 days of receiving the notice and accompanying information, the Receiving
24 Party may produce the Non-Party’s confidential information responsive to the
25 discovery request. If the Non-Party timely seeks a protective order, the Receiving
26 Party shall not produce any information in its possession or control that is subject to
27 the confidentiality agreement with the Non-Party before a determination by the court.
28
STIPULATED PROTECTIVE ORDER
- 11 -

1 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
2 of seeking protection in this court of its Protected Material.
3

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

4

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

5 Protected Material to any person or in any circumstance not authorized under this
6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
7 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
8 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
9 persons to whom unauthorized disclosures were made of all the terms of this Order,

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 and (d) request such person or persons to execute the “Acknowledgment and
11 Agreement to Be Bound” that is attached hereto as Exhibit A.
12

INADVERTENT PRODUCTION OF PRIVILEGED OR

13

OTHERWISE PROTECTED MATERIAL

14

When a Producing Party gives notice to Receiving Parties that certain

15 inadvertently produced material is subject to a claim of privilege or other protection,
16 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
17 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
18 may be established in an e-discovery order that provides for production without prior
19 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
20 parties reach an agreement on the effect of disclosure of a communication or
21 information covered by the attorney-client privilege or work product protection, the
22 parties may incorporate their agreement in the stipulated protective order submitted to
23 the court.
24

MISCELLANEOUS

25

12.1 Right to Further Relief. Nothing in this Order abridges the right of any

26 person to seek its modification by the Court in the future.
27

12.2 Right to Assert Other Objections. By stipulating to the entry of this

28 Protective Order no Party waives any right it otherwise would have to object to
STIPULATED PROTECTIVE ORDER
- 12 -

1 disclosing or producing any information or item on any ground not addressed in this
2 Stipulated Protective Order. Similarly, no Party waives any right to object on any
3 ground to use in evidence of any of the material covered by this Protective Order.
4

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

5 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
6 only be filed under seal pursuant to a court order authorizing the sealing of the
7 specific Protected Material at issue. If a Party’s request to file Protected Material
8 under seal is denied by the court, then the Receiving Party may file the information in
9 the public record unless otherwise instructed by the court.

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10

FINAL DISPOSITION

11

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

12 days of a written request by the Designating Party, each Receiving Party must return
13 all Protected Material to the Producing Party or destroy such material. As used in this
14 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
15 summaries, and any other format reproducing or capturing any of the Protected
16 Material.

Whether the Protected Material is returned or destroyed, the Receiving

17 Party must submit a written certification to the Producing Party (and, if not the same
18 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
19 (by category, where appropriate) all the Protected Material that was returned or
20 destroyed and (2) affirms that the Receiving Party has not retained any copies,
21 abstracts, compilations, summaries or any other format reproducing or capturing any
22 of the Protected Material.

Notwithstanding this provision, Counsel are entitled to

23 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
24 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
25 reports, attorney work product, and consultant and expert work product, even if such
26 materials contain Protected Material.

Any such archival copies that contain or

27 constitute Protected Material remain subject to this Protective Order as set forth in
28 Section 4 (DURATION).
STIPULATED PROTECTIVE ORDER
- 13 -

1

VIOLATION

2

Any violation of this Order may be punished by any and all appropriate

3 measures including, without limitation, contempt proceedings and/or monetary
4 sanctions.
5
6

IT IS SO STIPULATED

7
8 Dated: May 16, 2019

REED SMITH LLP

9

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10

By:

11

Raffi Kassabian
Attorneys for Defendant
Synchrony Bank

12
13
14

17
Dated: May __, 2019

/s/ Ahmad Karimkhani
_________________________________
Ahmad Karimkhani
Plaintiff

17
Dated: May __, 2019

Monireh Karimkhani
/s/
_________________________________
Monireh Karimkhani
Plaintiff

15
16
17
18
19
20
21
22
23

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

24
25
26
27

DATED: May 21, 2019
Hon. Kenly Kiya Kato
United States Magistrate Judge

28
STIPULATED PROTECTIVE ORDER
- 14 -

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

I, ____________________ [print or type full name], of ___________________

4 [print or type full address], declare under penalty of perjury that I have read in its
5 entirety and understand the Stipulated Protective Order that was issued by the United
6 States District Court for the Central District of California, Ahmad Karimkhani and
7 Monireh Karimkhani v. Real Time Resolutions, Inc., et al., Case No. 5:18-cv-007308 JGB-KK. I agree to comply with and to be bound by all the terms of this Stipulated
9 Protective Order and I understand and acknowledge that failure to so comply could

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 expose me to sanctions and punishment in the nature of contempt. I solemnly promise
11 that I will not disclose in any manner any information or item that is subject to this
12 Stipulated Protective Order to any person or entity except in strict compliance with the
13 provisions of this Order. I further agree to submit to the jurisdiction of the United
14 States District Court for the Central District of California for the purpose of enforcing
15 the terms of this Stipulated Protective Order, even if such enforcement proceedings
16 occur after termination of this action. I hereby appoint ___________________ [print
17 or type full name] of _____________ [print or type full address and telephone
18 number] as my California agent for service of process in connection with this action or
19 any proceedings related to enforcement of this Stipulated Protective Order.
20
21
22
23

Date:
City and State where sworn and signed:
Printed name:
Signature:

24
25
26
27
28

–1–
STIPULATED PROTECTIVE ORDER