QDOS, Inc. v. James H Donell

Filing 23

STIPULATED PROTECTIVE ORDER by Judge Manuel L. Real, re Stipulation 22 . See document for details. (gk)

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1 2 3 4 5 6 7 8 9 10 11 12 Damian D. Capozzola (SBN 186412) Timothy R. Laquer (SBN 306917) 555 W. Fifth Street, 31st Floor Los Angeles, California 90013 Phone: (213) 533-4112 Facsimile: (213) 996-8304 ddc@ddclaw.com trl@ddclaw.com Anthony C. Modarelli III (SBN 286520) Turner & Modarelli, PC 5000 Birch St., Suite 3000 Newport Beach, CA 92660 Phone: (949) 610-0855 Facsimile: (866) 83305594 Anthony@tmodlaw.com Counsel for Plaintiff, QDOS, Inc., a Delaware Corporation 13 UNITED STATES DISTRICT COURT 14 FOR THE CENTRAL DISTRICT OF CALIFORNIA 15 16 17 18 19 20 21 22 23 24 25 26 27 QDOS, INC., a Delaware Corporation, ) ) ) Plaintiff, ) ) ) ) vs. ) ) ) ) JAMES H. DONELL, RECEIVER ) ) FOR J.T. WALLENBROCK & ) ASSOCIATES and CITADEL ) CAPITAL MANAGEMENT GROUP, ) INC., ) ) ) Defendants. ) ) Case No.: 8:16-cv-01472-R-KES Assigned To: Hon. Manuel Real STIPULATED PROTECTIVE ORDER 28 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -1- 1 2 1. A. PURPOSES AND LIMITATIONS 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 may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court 6 to enter the following Stipulated Protective Order. The parties acknowledge that 7 this Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. B. GOOD CAUSE STATEMENT 11 12 This action is likely to involve trade secrets, trademarks, patents, customer 13 lists, pricing lists and other valuable research, development, commercial, 14 financial, technical and/or proprietary information for which special protection 15 from public disclosure and from use for any purpose other than prosecution of this 16 action is warranted. Such confidential and proprietary materials and information 17 consist of, among other things, confidential business or financial information, 18 information regarding confidential business practices, or other confidential 19 research, development, or commercial information (including information 20 implicating privacy rights of third parties), information otherwise generally 21 unavailable to the public, or which may be privileged or otherwise protected from 22 disclosure under state or federal statutes, court rules, case decisions, or common 23 law. Accordingly, to expedite the flow of information, to facilitate the prompt 24 resolution of disputes over confidentiality of discovery materials, to adequately 25 protect information the parties are entitled to keep confidential, to ensure that the 26 parties are permitted reasonable necessary uses of such material in preparation for 27 and in the conduct of trial, to address their handling at the end of the litigation, 28 and serve the ends of justice, a protective order for such information is justified in 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -2- 1 this matter. It is the intent of the parties that information will not be designated as 2 confidential for tactical reasons and that nothing be so designated without a good 3 faith belief that it has been maintained in a confidential, non-public manner, and 4 there is good cause why it should not be part of the public record of this case. 5 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING 6 UNDER SEAL 7 The parties further acknowledge, as set forth in Section 12.3, below, that 8 this Stipulated Protective Order does not entitle them to file confidential 9 information under seal; Local Civil Rule 79-5 sets forth the procedures that must 10 be followed and the standards that will be applied when a party seeks permission 11 from the court to file material under seal. 12 There is a strong presumption that the public has a right of access to judicial 13 proceedings and records in civil cases. In connection with non-dispositive 14 motions, good cause must be shown to support a filing under seal. See Kamakana 15 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. 16 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. 17 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 18 protective orders require good cause showing), and a specific showing of good 19 cause or compelling reasons with proper evidentiary support and legal 20 justification, must be made with respect to Protected Material that a party seeks to 21 file under seal. The parties’ mere designation of Disclosure or Discovery Material 22 as CONFIDENTIAL does not—without the submission of competent evidence by 23 declaration, establishing that the material sought to be filed under seal qualifies as 24 confidential, privileged, or otherwise protectable—constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, then 26 compelling reasons, not only good cause, for the sealing must be shown, and the 27 relief sought shall be narrowly tailored to serve the specific interest to be 28 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -3- 1 2010). For each item or type of information, document, or thing sought to be filed 2 or introduced under seal in connection with a dispositive motion or trial, the party 3 seeking protection must articulate compelling reasons, supported by specific facts 4 and legal justification, for the requested sealing order. Again, competent evidence 5 supporting the application to file documents under seal must be provided by 6 declaration. 7 Any document that is not confidential, privileged, or otherwise protectable 8 in its entirety will not be filed under seal if the confidential portions can be 9 redacted. If documents can be redacted, then a redacted version for public 10 viewing, omitting only the confidential, privileged, or otherwise protectable 11 portions of the document, shall be filed. Any application that seeks to file 12 documents under seal in their entirety should include an explanation of why 13 redaction is not feasible. 14 2. DEFINITIONS 15 2.1 Action: This pending federal lawsuit with Case No.: 8:16-cv-01472- 16 17 18 19 R-KES 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 20 of how it is generated, stored or maintained) or tangible things that qualify for 21 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 22 the Good Cause Statement. 23 24 25 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 26 or items that it produces in disclosures or in responses to discovery as 27 “CONFIDENTIAL.” 28 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -4- 1 2.6 Disclosure or Discovery Material: All items or information, 2 regardless of the medium or manner in which it is generated, stored, or maintained 3 (including, among other things, testimony, transcripts, and tangible things), that 4 are produced or generated in disclosures or responses to discovery in this matter. 5 2.7 Expert: A person with specialized knowledge or experience in a 6 matter pertinent to the litigation who has been retained by a Party or its counsel to 7 serve as an expert witness or as a consultant in this Action. 8 9 2.8 House Counsel: Attorneys who are employees of a party to this Action. House Counsel does not include Outside Counsel of Record or any other 10 outside counsel. 11 2.9 12 13 Non-Party: Any natural person, partnership, corporation, association or other legal entity not named as a Party to this action. 2.10 Outside Counsel of Record: Attorneys who are not employees of a 14 party to this Action but are retained to represent or advise a party to this Action 15 and have appeared in this Action on behalf of that party or are affiliated with a law 16 firm that has appeared on behalf of that party, and includes support staff. 17 2.11 Party: Any party to this Action, including all of its officers, 18 directors, employees, consultants, retained experts, and Outside Counsel of 19 Record (and their support staffs). 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 2.14 Protected Material: Any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 28 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -5- 1 2 2.15 Receiving Party: A Party that receives Disclosure or Discovery Material from a Producing Party. 3 3. 4 The protections conferred by this Stipulation and Order cover not only 5 Protected Material (as defined above), but also (1) any information copied or 6 extracted from Protected Material; (2) all copies, excerpts, summaries, or 7 compilations of Protected Material; and (3) any testimony, conversations, or 8 presentations by Parties or their Counsel that might reveal Protected Material. 9 Any use of Protected Material at trial shall be governed by the orders of the trial 10 11 SCOPE judge. This Order does not govern the use of Protected Material at trial. 4. DURATION Once a case proceeds to trial, information that was designated as 12 13 CONFIDENTIAL or maintained pursuant to this protective order used or 14 introduced as an exhibit at trial becomes public and will be presumptively 15 available to all members of the public, including the press, unless compelling 16 reasons supported by specific factual findings to proceed otherwise are made to 17 the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 18 (distinguishing “good cause” showing for sealing documents produced in 19 discovery from “compelling reasons” standard when merits-related documents are 20 part of court record). Accordingly, the terms of this protective order do not extend 21 beyond the commencement of the trial. 22 5. DESIGNATING PROTECTED MATERIAL 23 5.1 Exercise of Restraint and Care in Designating Material for Protection. 24 25 Each Party or Non-Party that designates information or items for protection 26 under this Order must take care to limit any such designation to specific material 27 that qualifies under the appropriate standards. The Designating Party must 28 designate for protection only those parts of material, documents, items or oral or 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -6- 1 written communications that qualify so that other portions of the material, 2 documents, items or communications for which protection is not warranted are not 3 swept unjustifiably within the ambit of this Order. 4 Mass, indiscriminate or routinized designations are prohibited. 5 Designations that are shown to be clearly unjustified or that have been made for 6 an improper purpose (e.g., to unnecessarily encumber the case development 7 process or to impose unnecessary expenses and burdens on other parties) may 8 expose the Designating Party to sanctions. 9 If it comes to a Designating Party’s attention that information or items that 10 it designated for protection do not qualify for protection, that Designating Party 11 must promptly notify all other Parties that it is withdrawing the inapplicable 12 designation. 13 5.2 Manner and Timing of Designations. 14 Except as otherwise provided in this Order (see, e.g., second paragraph of 15 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 16 Discovery Material that qualifies for protection under this Order must be clearly 17 so designated before the material is disclosed or produced. 18 Designation in conformity with this Order requires: 19 (a) for information in documentary form (e.g., paper or electronic 20 documents, but excluding transcripts of depositions or other pretrial or trial 21 proceedings), that the Producing Party affix at a minimum, the legend 22 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page 23 that contains protected material. If only a portion of the material on a page 24 qualifies for protection, the Producing Party also must clearly identify the 25 protected portion(s) (e.g., by making appropriate markings in the margins). A Party or Non-Party that makes original documents available for 26 27 inspection need not designate them for protection until after the inspecting 28 Party has indicated which documents it would like copied and produced. 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -7- 1 During the inspection and before the designation, all of the material made 2 available for inspection shall be deemed “CONFIDENTIAL.” After the 3 inspecting Party has identified the documents it wants copied and produced, 4 the Producing Party must determine which documents, or portions thereof, 5 qualify for protection under this Order. Then, before producing the 6 specified documents, the Producing Party must affix the “CONFIDENTIAL 7 legend” to each page that contains Protected Material. If only a portion of 8 the material on a page qualifies for protection, the Producing Party also 9 must clearly identify the protected portion(s) (e.g., by making appropriate 10 markings in the margins). 11 (b) for testimony given in depositions that the Designating Party identifies 12 the Disclosure or Discovery Material on the record, before the close of the 13 deposition all protected testimony. 14 (c) for information produced in some form other than documentary and for 15 any other tangible items, that the Producing Party affix in a prominent place 16 on the exterior of the container or containers in which the information is 17 stored the legend “CONFIDENTIAL.” If only a portion or portions of the 18 information warrants protection, the Producing Party, to the extent 19 practicable, shall identify the protected portion(s). 20 5.3 21 If timely corrected, an inadvertent failure to designate qualified information Inadvertent Failures to Designate. 22 or items does not, standing alone, waive the Designating Party’s right to secure 23 protection under this Order for such material. Upon timely correction of a 24 designation, the Receiving Party must make reasonable efforts to assure that the 25 material is treated in accordance with the provisions of this Order. 26 /// 27 /// 28 /// 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -8- 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. 3 Any Party or Non-Party may challenge a designation of confidentiality at 4 any time that is consistent with the Court’s Scheduling Order. 5 6.2 6 The Challenging Party shall initiate the dispute resolution process under 7 Local Rule 37.1 et seq. 6.3 8 9 Meet and Confer. The burden of persuasion in any such challenge proceeding shall be on the Designating Party. Frivolous challenges, and those made for an improper 10 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 11 parties) may expose the Challenging Party to sanctions. Unless the Designating 12 Party has waived or withdrawn the confidentiality designation, all parties shall 13 continue to afford the material in question the level of protection to which it is 14 entitled under the Producing Party’s designation until the Court rules on the 15 challenge. 16 7. ACCESS TO AND USE OF PROTECTED MATERIAL 17 7.1 Basic Principles. 18 A Receiving Party may use Protected Material that is disclosed or produced 19 by another Party or by a Non-Party in connection with this Action only for 20 prosecuting, defending or attempting to settle this Action. Such Protected 21 Material may be disclosed only to the categories of persons and under the 22 conditions described in this Order. When the Action has been terminated, a 23 Receiving Party must comply with the provisions of section 13 below (FINAL 24 DISPOSITION). Protected Material must be stored and maintained by a Receiving Party at a 25 26 location and in a secure manner that ensures that access is limited to the persons 27 authorized under this Order. 28 /// 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -9- 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 2 otherwise ordered by the court or permitted in writing by the Designating Party, a 3 Receiving Party may disclose any information or item designated 4 “CONFIDENTIAL” only to: 5 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 6 as employees of said Outside Counsel of Record to whom it is reasonably 7 necessary to disclose the information for this Action; 8 (b) the officers, directors, and employees (including House Counsel) of the 9 Receiving Party to whom disclosure is reasonably necessary for this Action; 10 (c) Experts (as defined in this Order) of the Receiving Party to whom 11 disclosure is reasonably necessary for this Action and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (d) the court and its personnel; 14 (e) court reporters and their staff; 15 (f) professional jury or trial consultants, mock jurors, and Professional 16 Vendors to whom disclosure is reasonably necessary for this Action and 17 who have signed the “Acknowledgment and Agreement to Be Bound” 18 (Exhibit A); 19 (g) the author or recipient of a document containing the information or a 20 custodian or other person who otherwise possessed or knew the 21 information; 22 (h) during their depositions, witnesses, and attorneys for witnesses, in the 23 Action to whom disclosure is reasonably necessary provided: (1) the 24 deposing party requests that the witness sign the form attached as Exhibit 1 25 hereto; and (2) they will not be permitted to keep any confidential 26 information unless they sign the “Acknowledgment and Agreement to Be 27 Bound” (Exhibit A), unless otherwise agreed by the Designating Party or 28 ordered by the court. Pages of transcribed deposition testimony or exhibits 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -10- 1 to depositions that reveal Protected Material may be separately bound by 2 the court reporter and may not be disclosed to anyone except as permitted 3 under this Stipulated Protective Order; and 4 (i) any mediator or settlement officer, and their supporting personnel, 5 mutually agreed upon by any of the parties engaged in settlement 6 discussions. 7 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 8 9 If a Party is served with a subpoena or a court order issued in other 10 litigation that compels disclosure of any information or items designated in this 11 Action as “CONFIDENTIAL,” that Party must: 12 (a) promptly notify in writing the Designating Party. Such notification 13 shall include a copy of the subpoena or court order; 14 (b) promptly notify in writing the party who caused the subpoena or order 15 to issue in the other litigation that some or all of the material covered by the 16 subpoena or order is subject to this Protective Order. Such notification 17 shall include a copy of this Stipulated Protective Order; and 18 (c) cooperate with respect to all reasonable procedures sought to be 19 pursued by the Designating Party whose Protected Material may be 20 affected. 21 If the Designating Party timely seeks a protective order, the Party served 22 with the subpoena or court order shall not produce any information designated in 23 this action as “CONFIDENTIAL” before a determination by the court from which 24 the subpoena or order issued, unless the Party has obtained the Designating 25 Party’s permission. The Designating Party shall bear the burden and expense of 26 seeking protection in that court of its confidential material and nothing in these 27 provisions should be construed as authorizing or encouraging a Receiving Party in 28 this Action to disobey a lawful directive from another court. 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -11- 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 2 3 (a) The terms of this Order are applicable to information produced by a 4 Non-Party in this Action and designated as “CONFIDENTIAL.” Such 5 information produced by Non-Parties in connection with this litigation is 6 protected by the remedies and relief provided by this Order. Nothing in 7 these provisions should be construed as prohibiting a Non-Party from 8 seeking additional protections. 9 (b) In the event that a Party is required, by a valid discovery request, to 10 produce a Non-Party’s confidential information in its possession, and the 11 Party is subject to an agreement with the Non-Party not to produce the Non- 12 Party’s confidential information, then the Party shall: 13 (1) promptly notify in writing the Requesting Party and the Non- 14 Party that some or all of the information requested is subject to a 15 confidentiality agreement with a Non-Party; 16 (2) promptly provide the Non-Party with a copy of the Stipulated 17 Protective Order in this Action, the relevant discovery request(s), and 18 a reasonably specific description of the information requested; and 19 (3) make the information requested available for inspection by the 20 Non-Party, if requested. 21 (c) If the Non-Party fails to seek a protective order from this court within 22 14 days of receiving the notice and accompanying information, the 23 Receiving Party may produce the Non-Party’s confidential information 24 responsive to the discovery request. If the Non-Party timely seeks a 25 protective order, the Receiving Party shall not produce any information in 26 its possession or control that is subject to the confidentiality agreement with 27 the Non-Party before a determination by the court. Absent a court order to 28 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -12- 1 the contrary, the Non-Party shall bear the burden and expense of seeking 2 protection in this court of its Protected Material. 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 5 If a Receiving Party learns that, by inadvertence or otherwise, it has 6 disclosed Protected Material to any person or in any circumstance not authorized 7 under this Stipulated Protective Order, the Receiving Party must immediately (a) 8 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 9 best efforts to retrieve all unauthorized copies of the Protected Material, (c) 10 inform the person or persons to whom unauthorized disclosures were made of all 11 the terms of this Order, and (d) request such person or persons to execute the 12 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 13 A. 14 11. OTHERWISE PROTECTED MATERIAL 15 16 INADVERTENT PRODUCTION OF PRIVILEGED OR When a Producing Party gives notice to Receiving Parties that certain 17 inadvertently produced material is subject to a claim of privilege or other 18 protection, the obligations of the Receiving Parties are those set forth in Federal 19 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 20 whatever procedure may be established in an e-discovery order that provides for 21 production without prior privilege review. Pursuant to Federal Rule of Evidence 22 502(d) and (e), insofar as the parties reach an agreement on the effect of 23 disclosure of a communication or information covered by the attorney-client 24 privilege or work product protection, the parties may incorporate their agreement 25 in the stipulated protective order submitted to the court. 26 12. MISCELLANEOUS 27 12.1 Right to Further Relief. 28 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -13- 1 2 Nothing in this Order abridges the right of any person to seek its modification by the Court in the future. 3 12.2 Right to Assert Other Objections. 4 By stipulating to the entry of this Protective Order, no Party waives any 5 right it otherwise would have to object to disclosing or producing any information 6 or item on any ground not addressed in this Stipulated Protective Order. 7 Similarly, no Party waives any right to object on any ground to use in evidence of 8 any of the material covered by this Protective Order. 9 10 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected Material must comply 11 with Local Civil Rule 79-5. Protected Material may only be filed under seal 12 pursuant to a court order authorizing the sealing of the specific Protected Material 13 at issue. If a Party’s request to file Protected Material under seal is denied by the 14 court, then the Receiving Party may file the information in the public record 15 unless otherwise instructed by the court. 16 13. 17 After the final disposition of this Action, as defined in paragraph 4, within 18 60 days of a written request by the Designating Party, each Receiving Party must 19 return all Protected Material to the Producing Party or destroy such material, 20 except to the extent that James H. Donell, Receiver, is required either by court 21 order or by virtue of his duties as a Receiver appointed by the United States 22 District Court to retain any such Protected Material, he shall be entitled to refuse 23 to comply with such a written request by notifying QDOS, Inc. in writing of such 24 refusal within five court days. QDOS, Inc. shall file any objection to such refusal 25 within ten court days of receiving notice of such refusal. As used in this 26 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 27 summaries, and any other format reproducing or capturing any of the Protected 28 Material. Whether the Protected Material is returned or destroyed, the Receiving 13390.2:2774130.1 FINAL DISPOSITION STIPULATED PROTECTIVE ORDER -14- 1 Party must submit a written certification to the Producing Party (and, if not the 2 same person or entity, to the Designating Party) by the 60 day deadline that (1) 3 identifies (by category, where appropriate) all the Protected Material that was 4 returned or destroyed and (2) affirms that the Receiving Party has not retained any 5 copies, abstracts, compilations, summaries or any other format reproducing or 6 capturing any of the Protected Material. Notwithstanding this provision, Counsel 7 are entitled to retain an archival copy of all pleadings, motion papers, trial, 8 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 9 and trial exhibits, expert reports, attorney work product, and consultant and expert 10 work product, even if such materials contain Protected Material. Any such 11 archival copies that contain or constitute Protected Material remain subject to this 12 Protective Order as set forth in Section 4 (DURATION). 13 14. VIOLATION 14 Any violation of this Order may be punished by appropriate measures 15 including, without limitation, contempt proceedings and/or monetary sanctions. 16 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 17 18 DATED: October 7, 2016 TURNER & MODARELLI, PC 19 ____________________________________ 20 By: Anthony C. Modarelli Attorney for Plaintiff, QDOS, Inc. 21 22 23 DATED: October 7, 2016 ERVIN COHEN & JESSUP LLP 24 _____/s/ Byron Z. Moldo_________________ 25 By: Byron Z. Moldo Attorneys for Defendant, James H. Donell, Receiver 26 27 28 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -15- 1 As the filer of this document, I attest that all other signatories listed on 2 whose behalf the filing is submitted, concur in the filing's content and have 3 authorized the filing. 4 DATED: October 7, 2016 TURNER & MODARELLI, PC 5 6 _____________________________________ 7 By: Anthony C. Modarelli 8 Plaintiff, QDOS, Inc. Attorney for 9 10 11 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 12 13 DATED: October 11, 2016 14 15 _____________________________________ 16 HON. MANUEL L. REAL 17 United States District Court Judge 18 19 20 21 22 23 24 25 26 27 28 13390.2:2774130.1 STIPULATED PROTECTIVE ORDER -16-

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