Marilyn Cochoit v. Schiff Nutrition International, Inc. et al

Filing 30

STIPULATED PROTECTIVE ORDER by Magistrate Judge Karen E. Scott: See document for further information. (lwag)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 MANATT, PHELPS & PHILLIPS, LLP ROBERT H. PLATT (SBN 108533) E-mail: ADRIANNE E. MARSHACK (SBN 253682) E-mail: CARY L. FINKELSTEIN (SBN 302138) E-mail: 695 Town Center Drive, 14th Floor Costa Mesa, CA 92626 Telephone: (714) 371-2500 Facsimile: (714) 371-2550 Attorneys for Defendant RECKITT BENCKISER LLC LAW OFFICES OF
 RONALD A. MARRON (SBN 175650) E-mail:
 MICHAEL T. HOUCHIN (SBN 305541) E-mail: 651 Arroyo Drive
 San Diego, California 92103
 Telephone: (619) 696-9006
 Facsimile: (619) 564-6665 Counsel for Plaintiff and the Proposed Class 16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18 19 MARILYN COCHOIT, on behalf of Case No.: 8:16-cv-01371 CJC (KESx) herself, all others similarly situated, CLASS ACTION and the general public, 20 21 22 23 24 25 26 Plaintiff, v. SCHIFF NUTRITION INTERNATIONAL INC., SCHIFF NUTRITION GROUP INC., GANEDEN BIOTECH, INC. RECKITT BENCKISER LLC., STIPULATED PROTECTIVE ORDER [Discovery Document: Referred to Magistrate Judge Karen E. Scott] Defendants. 27 28 STIPULATED PROTECTIVE ORDER 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation 5 may be warranted. Accordingly, the parties hereby stipulate to and petition the 6 Court to enter the following Stipulated Protective Order. 7 acknowledge that this Order does not confer blanket protections on all 8 disclosures or responses to discovery and that the protection it affords from 9 public disclosure and use extends only to the limited information or items that 10 are entitled to confidential treatment under the applicable legal principles. The 11 parties further acknowledge, as set forth in Section 12.3, below, that this 12 Stipulated Protective Order does not entitle them to file confidential information 13 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed 14 and the standards that will be applied when a party seeks permission from the 15 court to file material under seal. The parties 16 B. GOOD CAUSE STATEMENT 17 This action is likely to involve trade secrets, customer and pricing lists, 18 sales data, advertising and marketing strategies, product testing, product 19 research and development, and other valuable commercial, financial, technical 20 and/or proprietary information for which special protection from public 21 disclosure and from use for any purpose other than prosecution of this action is 22 warranted. Such confidential and proprietary materials and information consist 23 of, among other things, confidential business or financial information, 24 information regarding confidential business practices, or other confidential 25 research, development, or commercial information (including information 26 implicating privacy rights of third parties), information otherwise generally 27 unavailable to the public, or which may be privileged or otherwise protected 28 from disclosure under state or federal statutes, court rules, case decisions, or common law. Accordingly, to expedite the flow of information, to facilitate the prompt resolution of disputes over confidentiality of discovery materials, to 1 STIPULATED PROTECTIVE ORDER 1 adequately protect information the parties are entitled to keep confidential, to 2 ensure that the parties are permitted reasonable necessary uses of such material 3 in preparation for and in the conduct of trial, to address their handling at the end 4 of the litigation, and serve the ends of justice, a protective order for such 5 information is justified in this matter. 6 information will not be designated as confidential for tactical reasons and that 7 nothing be so designated without a good faith belief that it has been maintained 8 in a confidential, non-public manner, and there is good cause why it should not 9 be part of the public record of this case. 10 11 2. It is the intent of the parties that DEFINITIONS 2.1 Action: This pending federal lawsuit, entitled Marilyn Cochoit v. 12 Schiff Nutrition International Inc., et al., United States District Court for the 13 Central District of California Case No. 8:16-cv-01371-CJC-KES. 14 15 16 2.2 Challenging Party: A Party or Non-Party that challenges the designation of information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless 17 of how it is generated, stored or maintained) or tangible things that qualify for 18 protection under Federal Rule of Civil Procedure 26(c), and as specified above 19 in the Good Cause Statement. 20 21 22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 2.5 Designating Party: a Party or Non-Party that designates information 23 or items that it produces in disclosures or in responses to discovery as 24 “CONFIDENTIAL.” 25 2.6 Disclosure or Discovery Material: all items or information, 26 regardless of the medium or manner in which it is generated, stored, or 27 maintained (including, among other things, testimony, transcripts, and tangible 28 things), that are produced or generated in disclosures or responses to discovery in this matter. 2 STIPULATED PROTECTIVE ORDER 1 2.7 Expert: a person with specialized knowledge or experience in a 2 matter pertinent to the litigation who has been retained by a Party or its counsel 3 to serve as an expert witness or as a consultant in this Action. 4 2.8 House Counsel: attorneys who are employees of a party to this 5 Action. House Counsel does not include Outside Counsel of Record or any 6 other outside counsel. 7 8 2.9 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 9 2.10 Outside Counsel of Record: attorneys who are not employees of a 10 party to this Action but are retained to represent or advise a party to this Action 11 and have appeared in this Action on behalf of that party or are affiliated with a 12 law firm which has appeared on behalf of that party, and includes support staff. 13 2.11 Party: any party to this Action, including all of its officers, 14 directors, employees, consultants, retained experts, and Outside Counsel of 15 Record (and their support staffs). “Party” shall include any named plaintiff, but 16 shall not include any other putative class member. If a class is certified in the 17 Action, then a member of the class who is not a named plaintiff may see 18 Protected Material only if he or she reviews and signs Exhibit A hereto, and 19 agrees to be bound by the terms of this Order. 20 21 22 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 2.13 Professional Vendors: persons or entities that provide litigation 23 support services (e.g., photocopying, videotaping, translating, preparing exhibits 24 or demonstrations, and organizing, storing, or retrieving data in any form or 25 medium) and their employees and subcontractors. 26 27 28 2.14 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL” or “ATTORNEYS EYES ONLY.” 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party. 3 STIPULATED PROTECTIVE ORDER 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of 8 the trial judge. This Order does not govern the use of Protected Material at trial. 9 4. DURATION 10 Even after final disposition of this litigation, the confidentiality 11 obligations imposed by this Order shall remain in effect until a Designating 12 Party agrees otherwise in writing or a court order otherwise directs. Final 13 disposition shall be deemed to be the later of (1) dismissal of all claims and 14 defenses in this Action, with or without prejudice; and (2) final judgment herein 15 after the completion and exhaustion of all appeals, rehearings, remands, trials, or 16 reviews of this Action, including the time limits for filing any motions or 17 applications for extension of time pursuant to applicable law. 18 5. 19 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for 20 Protection. Each Party or Non-Party that designates information or items for 21 protection under this Order must take care to limit any such designation to 22 specific material that qualifies under the appropriate standards. The Designating 23 Party must designate for protection only those parts of material, documents, 24 items, or oral or written communications that qualify so that other portions of 25 the material, documents, items, or communications for which protection is not 26 warranted are not swept unjustifiably within the ambit of this Order. 27 28 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber the case development process or to impose unnecessary expenses and burdens on other parties) may 4 STIPULATED PROTECTIVE ORDER 1 expose the Designating Party to sanctions. 2 If it comes to a Designating Party’s attention that information or items 3 that it designated for protection do not qualify for protection, that Designating 4 Party must promptly notify all other Parties that it is withdrawing the 5 inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided 7 in this Order (see, e.g., second paragraph of section 5.2(a) below), or as 8 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies 9 for protection under this Order must be clearly so designated before the material 10 is disclosed or produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions or other pretrial or trial 14 proceedings), that the Producing Party affix at a minimum, the legend 15 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 16 contains protected material. If only a portion or portions of the material on a 17 page qualifies for protection, the Producing Party also must clearly identify the 18 protected portion(s) (e.g., by making appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for 20 inspection need not designate them for protection until after the inspecting Party 21 has indicated which documents it would like copied and produced. During the 22 inspection and before the designation, all of the material made available for 23 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 24 identified the documents it wants copied and produced, the Producing Party 25 must determine which documents, or portions thereof, qualify for protection 26 under this Order. 27 Producing Party must affix the “CONFIDENTIAL legend” to each page that 28 contains Protected Material. If only a portion or portions of the material on a Then, before producing the specified documents, the page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). 5 STIPULATED PROTECTIVE ORDER 1 (b) for testimony given in depositions that the Designating Party 2 identify the protected testimony and/or exhibits that are protected on the record 3 before the close of the deposition whenever possible. 4 designate such testimony and exhibits after transcription of the proceedings; a 5 Party shall have until twenty (20) days after receipt of the deposition transcript 6 to inform the other Party or Parties of the portions of the transcript so 7 designated. A Party may also 8 (c) for information produced in some form other than documentary 9 and for any other tangible items, that the Producing Party affix in a prominent 10 place on the exterior of the container or containers in which the information is 11 stored the legend “CONFIDENTIAL.” If only a portion or portions of the 12 information warrants protection, the Producing Party, to the extent practicable, 13 shall identify the protected portion(s). 5.3 14 Inadvertent Failures to Designate. If timely corrected, an 15 inadvertent failure to designate qualified information or items does not, standing 16 alone, waive the Designating Party’s right to secure protection under this Order 17 for such material. Upon timely correction of a designation, the Receiving Party 18 must make reasonable efforts to assure that the material is treated in accordance 19 with the provisions of this Order. 20 6. 21 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 22 designation of confidentiality at any time that is consistent with the Court’s 23 Scheduling Order. 24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 25 resolution process (and, if necessary, file a discovery motion) under Local Rule 26 37.1 et seq. 27 28 6.3 The burden of persuasion in any such challenge proceeding shall be on the Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the Designating 6 STIPULATED PROTECTIVE ORDER 1 Party has waived or withdrawn the confidentiality designation, all parties shall 2 continue to afford the material in question the level of protection to which it is 3 entitled under the Producing Party’s designation until the Court rules on the 4 challenge. 5 7. 6 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material 7 that is disclosed or produced by another Party or by a Non-Party in connection 8 with this Action only for prosecuting, defending, or attempting to settle this 9 Action. Such Protected Material may be disclosed only to the categories of 10 persons and under the conditions described in this Order. When the Action has 11 been terminated, a Receiving Party must comply with the provisions of section 12 13 below (FINAL DISPOSITION). 13 Protected Material must be stored and maintained by a Receiving Party at 14 a location and in a secure manner that ensures that access is limited to the 15 persons authorized under this Order. 16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 17 otherwise ordered by the court or permitted in writing by the Designating Party, 18 a Receiving Party may disclose any information or item designated 19 “CONFIDENTIAL” only to: 20 (a) the Receiving Party’s Outside Counsel of Record in this 21 Action, as well as employees of said Outside Counsel of Record to whom it is 22 reasonably necessary to disclose the information for this Action; (b) 23 the officers, directors, and employees (including House 24 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for 25 this Action; 26 (c) Experts (as defined in this Order) of the Receiving Party to 27 whom disclosure is reasonably necessary for this Action and who have signed 28 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (d) the Court and its personnel; (e) court reporters and their staff; 7 STIPULATED PROTECTIVE ORDER (f) 1 professional jury or trial consultants, mock jurors, and 2 Professional Vendors to whom disclosure is reasonably necessary for this Action 3 and who have signed the “Acknowledgment and Agreement to Be Bound” 4 (Exhibit A); (g) 5 the author or recipient of a document containing the 6 information or a custodian or other person who otherwise possessed or knew the 7 information; (h) 8 during their depositions, witnesses, and attorneys for 9 witnesses, in the Action to whom disclosure is reasonably necessary provided: 10 (1) the deposing party requests that the witness sign the form attached as Exhibit 11 A hereto; and (2) they will not be permitted to keep any confidential information 12 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit 13 A), unless otherwise agreed by the Designating Party or ordered by the court. 14 Pages of transcribed deposition testimony or exhibits to depositions that reveal 15 Protected Material may be separately bound by the court reporter and may not 16 be disclosed to anyone except as permitted under this Stipulated Protective 17 Order; and (i) 18 any mediator or settlement officer, and their supporting 19 personnel, mutually agreed upon by any of the parties engaged in settlement 20 discussions. 21 8. 22 PRODUCED IN OTHER LITIGATION PROTECTED MATERIAL SUBPOENAED OR ORDERED 23 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 25 Action as “CONFIDENTIAL,” that Party must: 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 8 STIPULATED PROTECTIVE ORDER 1 notification shall include a copy of this Stipulated Protective Order; and (c) 2 3 cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 4 If the Designating Party timely seeks a protective order, the Party served 5 with the subpoena or court order shall not produce any information designated in 6 this action as “CONFIDENTIAL” before a determination by the court from 7 which the subpoena or order issued, unless the Party has obtained the 8 Designating Party’s permission. The Designating Party shall bear the burden 9 and expense of seeking protection in that court of its confidential material and 10 nothing in these provisions should be construed as authorizing or encouraging a 11 Receiving Party in this Action to disobey a lawful directive from another court. 12 9. 13 PRODUCED IN THIS LITIGATION A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 14 (a) The terms of this Order are applicable to information produced 15 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 16 information produced by Non-Parties in connection with this litigation is 17 protected by the remedies and relief provided by this Order. Nothing in these 18 provisions should be construed as prohibiting a Non-Party from seeking 19 additional protections. 20 (b) In the event that a Party is required, by a valid discovery 21 request, to produce a Non-Party’s confidential information in its possession, and 22 the Party is subject to an agreement with the Non-Party not to produce the Non- 23 Party’s confidential information, then the Party shall: 24 (1) promptly notify in writing the Requesting Party and the 25 Non-Party that some or all of the information requested is subject to 26 a confidentiality agreement with a Non-Party; 27 (2) promptly provide the Non-Party with a copy of the 28 Stipulated Protective Order in this Action, the relevant discovery request(s), and a reasonably specific description of the information requested; and 9 STIPULATED PROTECTIVE ORDER (3) make the information requested available for inspection 1 2 by the Non-Party, if requested. 3 (c) If the Non-Party fails to seek a protective order from this court 4 within 14 days of receiving the notice and accompanying information, the 5 Receiving Party may produce the Non-Party’s confidential information 6 responsive to the discovery request. If the Non-Party timely seeks a protective 7 order, the Receiving Party shall not produce any information in its possession or 8 control that is subject to the confidentiality agreement with the Non-Party before 9 a determination by the court. Absent a court order to the contrary, the Non-Party 10 shall bear the burden and expense of seeking protection in this court of its 11 Protected Material. 12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has 14 disclosed Protected Material to any person or in any circumstance not authorized 15 under this Stipulated Protective Order, the Receiving Party must immediately (a) 16 notify in writing the Designating Party of the unauthorized disclosures, (b) use 17 its best efforts to retrieve all unauthorized copies of the Protected Material, (c) 18 inform the person or persons to whom unauthorized disclosures were made of all 19 the terms of this Order, and (d) request such person or persons to execute the 20 “Acknowledgment and Agreement to Be Bound” that is attached hereto as 21 Exhibit A. 22 11. 23 OTHERWISE PROTECTED MATERIAL INADVERTENT PRODUCTION OF PRIVILEGED OR 24 When a Producing Party gives notice to Receiving Parties that certain 25 inadvertently produced material is subject to a claim of privilege or other 26 protection, the obligations of the Receiving Parties are those set forth in Federal 27 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 28 whatever procedure may be established in an e-discovery order that provides for production without prior privilege review. The Parties further agree to be bound by the requirements of Federal Rule of Evidence 502, and hereby incorporate by 10 STIPULATED PROTECTIVE ORDER 1 reference the provisions of Federal Rule of Evidence 502. 2 12. 12.1 3 4 MISCELLANEOUS Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the Court in the future. 12.2 5 Right to Assert Other Objections. By stipulating to the entry of 6 this Protective Order no Party waives any right it otherwise would have to object 7 to disclosing or producing any information or item on any ground not addressed 8 in this Stipulated Protective Order. Similarly, no Party waives any right to object 9 on any ground to use in evidence of any of the material covered by this 10 Protective Order. 11 12.3 Filing Protected Material. A Party that seeks to file under seal any 12 Protected Material must comply with Civil Local Rule 79-5.1 Protected Material 13 may only be filed under seal pursuant to a court order authorizing the sealing of 14 the specific Protected Material at issue. If a Party's request to file Protected 15 Material under seal is denied by the court, then the Receiving Party may file the 16 information in the public record unless otherwise instructed by the court. 17 13. FINAL DISPOSITION 18 After the final disposition of this Action, as defined in paragraph 4, within 19 60 days of a written request by the Designating Party, each Receiving Party 20 must return all Protected Material to the Producing Party or destroy such 21 material. As used in this subdivision, “all Protected Material” includes all 22 copies, abstracts, compilations, summaries, and any other format reproducing or 23 capturing any of the Protected Material. Whether the Protected Material is 24 returned or destroyed, the Receiving Party must submit a written certification to 25 the Producing Party (and, if not the same person or entity, to the Designating 26 Party) by the 60 day deadline that (1) identifies (by category, where appropriate) 27 all the Protected Material that was returned or destroyed and (2) affirms that the 28 1 The Parties are directed to the Central District’s “Guide to Electronically Filing Under-Seal Documents in Civil Cases” (revised November 2015). 11 STIPULATED PROTECTIVE ORDER 1 Receiving Party has not retained any copies, abstracts, compilations, summaries 2 or any other format reproducing or capturing any of the Protected Material. 3 Notwithstanding this provision, Counsel are entitled to retain an archival copy of 4 all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 5 memoranda, correspondence, deposition and trial exhibits, expert reports, 6 attorney work product, and consultant and expert work product, even if such 7 materials contain Protected Material. Any such archival copies that contain or 8 constitute Protected Material remain subject to this Protective Order as set forth 9 in Section 4 (DURATION). 10 14. WILLFUL VIOLATION OF ORDER 11 Any willful violation of this Order may be punished by civil or criminal 12 contempt proceedings, financial or evidentiary sanctions, reference to 13 disciplinary authorities, or other appropriate action at the discretion of the Court. 14 15 16 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 17 18 19 Dated: February 3, 2017 20 LAW OFFICES OF RONALD A. MARRON /s/ Michael T. Houchin__________________ MICHAEL T. HOUCHIN Attorneys for Plaintiff and the Proposed Class 21 22 23 24 Dated: February 3, 2017 MANATT, PHELPS & PHILLIPS, LLP 25 26 27 28 /s/ Adrianne E. Marshack_________________ ADRIANNE E. MARSHACK Attorneys for Defendant RECKITT BENCKISER LLC 12 STIPULATED PROTECTIVE ORDER 1 SIGNATURE CERTIFICATION 2 Pursuant to Section 2(f)(4) of the Electronic Filing Administrative 3 Policies and Procedures Manual, I hereby certify that the content of this 4 document is acceptable to Michael T. Houchin, counsel for Plaintiff, and that I 5 have obtained Mr. Houchin’s authorization to affix his electronic signature to 6 this document. 7 Dated: February 3, 2017 8 MANATT, PHELPS & PHILLIPS, LLP By: /s/ Adrianne E. Marshack Adrianne E. Marshack 9 10 Attorneys for Defendant RECKITT BENCKISER LLC 11 12 13 14 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 15 16 17 DATED: February 07, 2017 _______________________________ Honorable Karen E. Scott United States Magistrate Judge 18 19 20 21 22 23 24 25 26 27 28 13 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [full name], of 4 _____________________________________________________[full address], 5 declare under penalty of perjury that I have read in its entirety and understand 6 the Stipulated Protective Order that was issued by the United States District 7 Court for the Central District of California on [date] in the case of Cochoit v. 8 Schiff Nutrition International Inc., et al. 8:16-cv-01371-CJC-KES (C.D. Cal. 9 Filed July 25, 2016). I agree to comply with and to be bound by all the terms of 10 this Stipulated Protective Order and I understand and acknowledge that failure 11 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 13 information or item that is subject to this Stipulated Protective Order to any 14 person or entity except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for the purpose of enforcing the 17 terms of this Stipulated Protective Order, even if such enforcement proceedings 18 occur after termination of this action. I hereby appoint 19 __________________________ [full name] of __________________________ 20 ________________________________________ [full address and telephone 21 number] as my California agent for service of process in connection with this 22 action or any proceedings related to enforcement of this Stipulated Protective 23 Order. 24 25 Date: ______________________________________ 26 City and State where signed: _________________________________ 27 28 Printed name: _______________________________ Signature:_______________________ 318237132 14 STIPULATED PROTECTIVE ORDER

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