Paul Wright v. Sirius XM Radio Inc.

Filing 56

STIPULATED PROTECTIVE ORDER by Magistrate Judge Jay C. Gandhi re Stipulation for Protective Order 52 . (kh)

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1 2 3 4 5 Tina Wolfson, SBN 174806 AHDOOT & WOLFSON, PC 1016 Palm Avenue West Hollywood, CA 90069 Tel: (310) 474-9111 Fax: (310) 474-8585 Lee A. Armstrong (pro hac vice) JONES DAY 250 Vesey Street New York, NY 10281-1047 Telephone: 212.326.8340 Facsimile: 212.755.7306 6 7 8 9 10 11 Cornelius P. Dukelow (pro hac vice) ABINGTON COLE + ELLERY 320 S. Boston Avenue, Suite 1130 Tulsa, OK 74103 Telephone & Facsimile: (918) 588-3400 John A Vogt (SBN 198677) JONES DAY 3161 Michelson Drive, Suite 800 Irvine, CA 92612.4408 Tel: 949.851.3939 Fax: 949.553.7539 Counsel for Plaintiff Counsel for Defendant 12 13 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA 16 SOUTHERN DIVISION 17 18 PAUL WRIGHT, individually and on behalf of all others similarly situated; 19 20 Case No. 8:16-cv-01688-JVS-JCG STIPULATED PROTECTIVE ORDER Plaintiff, vs. 21 22 23 SIRIUS XM RADIO INC., Defendant. 24 25 26 27 28 1 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG 1 1. PURPOSES AND LIMITATIONS Disclosure and discovery activity in this action are likely to involve production 2 3 of confidential, proprietary, or private information for which special protection from 4 public 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 court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to discovery 8 and that the protection it affords from public disclosure and use extends only to the 9 limited information or items that are entitled to confidential treatment under the 10 applicable legal principles. The parties further acknowledge, as set forth in Section 11 12.3, below, that this Stipulated Protective Order does not entitle them to file 12 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures 13 that must be followed and the standards that will be applied when a party seeks 14 permission from the court to file material under seal. 15 2. 16 17 18 DEFINITIONS 2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.2 “CONFIDENTIAL” Information or Items: information (regardless of 19 how it is generated, stored or maintained) or tangible things that qualify for protection 20 under Federal Rule of Civil Procedure 26(c). 21 22 23 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as their support staff). 2.4 Designating Party: a Party or Non-Party that designates information or 24 items that it produces in disclosures or in responses to discovery as 25 “CONFIDENTIAL.” 26 27 2.5 Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, 28 2 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG 1 among other things, testimony, transcripts, and tangible things), that are produced or 2 generated in disclosures or responses to discovery in this matter. 3 2.6 Expert: a person with specialized knowledge or experience in a matter 4 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 5 expert witness or as a consultant in this action. 6 2.7 House Counsel: attorneys who are employees of a party to this action. 7 House Counsel does not include Outside Counsel of Record or any other outside 8 counsel. 9 10 11 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.9 Outside Counsel of Record: attorneys who are not employees of a party 12 to this action but are retained to represent or advise a party to this action and have 13 appeared in this action on behalf of that party or are affiliated with a law firm which 14 has appeared on behalf of that party. 15 2.10 Party: any party to this action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 19 20 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action. 2.12 Professional Vendors: persons or entities that provide litigation support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 23 their employees and subcontractors. 24 25 26 27 2.13 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party. 28 3 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG 1 3. SCOPE The protections conferred by this Stipulation and Order cover not only Protected 2 3 Material (as defined above), but also (1) any information copied or extracted from 4 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 5 Material; and (3) any testimony, conversations, or presentations by Parties or their 6 Counsel that might reveal Protected Material. However, the protections conferred by 7 this Stipulation and Order do not cover the following information: (a) any information 8 that is in the public domain at the time of disclosure to a Receiving Party or becomes 9 part of the public domain after its disclosure to a Receiving Party as a result of 10 publication not involving a violation of this Order, including becoming part of the 11 public record through trial or otherwise; and (b) any information known to the 12 Receiving Party prior to the disclosure or obtained by the Receiving Party after the 13 disclosure from a source who obtained the information lawfully and under no 14 obligation of confidentiality to the Designating Party. Any use of Protected Material at 15 trial shall be governed by a separate agreement or order. 16 4. DURATION 17 Even after final disposition of this litigation, the confidentiality obligations 18 imposed by this Order shall remain in effect until a Designating Party agrees otherwise 19 in writing or a court order otherwise directs. Final disposition shall be deemed to be 20 the later of (1) dismissal of all claims and defenses in this action, with or without 21 prejudice; and (2) final judgment herein after the completion and exhaustion of all 22 appeals, rehearings, remands, trials, or reviews of this action, including the time limits 23 for filing any motions or applications for extension of time pursuant to applicable law. 24 5. 25 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 26 Each Party or Non-Party that designates information or items for protection under this 27 Order must take care to limit any such designation to specific material that qualifies 28 under the appropriate standards. The Designating Party must designate for protection 4 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG 1 only those parts of material, documents, items, or oral or written communications that 2 qualify – so that other portions of the material, documents, items, or communications 3 for which protection is not warranted are not swept unjustifiably within the ambit of 4 this Order. 5 Mass, indiscriminate, or routinized designations are prohibited. Designations 6 that are shown to be clearly unjustified or that have been made for an improper 7 purpose (e.g., to unnecessarily encumber or retard the case development process or to 8 impose unnecessary expenses and burdens on other parties) expose the Designating 9 Party to sanctions. 10 If it comes to a Designating Party’s attention that information or items that it 11 designated for protection do not qualify for protection, that Designating Party must 12 promptly notify all other Parties that it is withdrawing the mistaken designation. 13 5.2 Manner and Timing of Designations. Except as otherwise provided in this 14 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 15 or ordered, Disclosure or Discovery Material that qualifies for protection under this 16 Order must be clearly so designated before the material is disclosed or produced. 17 Designation in conformity with this Order requires: 18 (a) for information in documentary form (e.g., paper or electronic documents, 19 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 20 Producing Party affix the legend “CONFIDENTIAL” to each page that contains 21 protected material. If only a portion or portions of the material on a page qualifies for 22 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 23 by making appropriate markings in the margins). 24 A Party or Non-Party that makes original documents or materials available for 25 inspection need not designate them for protection until after the inspecting Party has 26 indicated which material it would like copied and produced. During the inspection and 27 before the designation, all of the material made available for inspection shall be 28 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents it 5 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG 1 wants copied and produced, the Producing Party must determine which documents, or 2 portions thereof, qualify for protection under this Order. Then, before producing the 3 specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to 4 each page that contains Protected Material. If only a portion or portions of the material 5 on a page qualifies for protection, the Producing Party also must clearly identify the 6 protected portion(s) (e.g., by making appropriate markings in the margins). 7 (b) for testimony given in deposition or in other pretrial or trial proceedings, 8 that the Designating Party identify on the record, before the close of the deposition, 9 hearing, or other proceeding, all protected testimony. (c) for information produced in some form other than documentary and for any 10 11 other tangible items, that the Producing Party affix in a prominent place on the exterior 12 of the container or containers in which the information or item is stored the legend 13 “CONFIDENTIAL.” If only a portion or portions of the information or item warrant 14 protection, the Producing Party, to the extent practicable, shall identify the protected 15 portion(s). 5.3 16 Inadvertent Failures to Designate. If timely corrected, an inadvertent 17 failure to designate qualified information or items does not, standing alone, waive the 18 Designating Party’s right to secure protection under this Order for such material. Upon 19 timely correction of a designation, the Receiving Party must make reasonable efforts to 20 assure that the material is treated in accordance with the provisions of this Order. 21 6. 22 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 23 designation of confidentiality at any time. Unless a prompt challenge to a Designating 24 Party’s confidentiality designation is necessary to avoid foreseeable, substantial 25 unfairness, unnecessary economic burdens, or a significant disruption or delay of the 26 litigation, a Party does not waive its right to challenge a confidentiality designation by 27 electing not to mount a challenge promptly after the original designation is disclosed. 28 6 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG 1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 2 resolution process by providing written notice of each designation it is challenging and 3 describing the basis for each challenge. To avoid ambiguity as to whether a challenge 4 has been made, the written notice must recite that the challenge to confidentiality is 5 being made in accordance with this specific paragraph of the Protective Order. The 6 parties shall attempt to resolve each challenge in good faith and must begin the process 7 by conferring directly (in voice to voice dialogue; other forms of communication are 8 not sufficient) within 14 days of the date of service of notice. In conferring, the 9 Challenging Party must explain the basis for its belief that the confidentiality 10 designation was not proper and must give the Designating Party an opportunity to 11 review the designated material, to reconsider the circumstances, and, if no change in 12 designation is offered, to explain the basis for the chosen designation. A Challenging 13 Party may proceed to the next stage of the challenge process only if it has engaged in 14 this meet and confer process first or establishes that the Designating Party is unwilling 15 to participate in the meet and confer process in a timely manner. 16 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without 17 court intervention, the Designating Party shall file and serve a motion to retain 18 confidentiality under Civil Local Rule 7 (and in compliance with Civil Local Rule 79- 19 5, if applicable) within 21 days of the initial notice of challenge or within 14 days of 20 the parties agreeing that the meet and confer process will not resolve their dispute, 21 whichever is earlier. Each such motion must be accompanied by a competent 22 declaration affirming that the movant has complied with the meet and confer 23 requirements imposed in the preceding paragraph. Failure by the Designating Party to 24 make such a motion including the required declaration within 21 days (or 14 days, if 25 applicable) shall automatically waive the confidentiality designation for each 26 challenged designation. In addition, the Challenging Party may file a motion 27 challenging a confidentiality designation at any time if there is good cause for doing 28 so, including a challenge to the designation of a deposition transcript or any portions 7 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG 1 thereof. Any motion brought pursuant to this provision must be accompanied by a 2 competent declaration affirming that the movant has complied with the meet and 3 confer requirements imposed by the preceding paragraph. 4 The burden of persuasion in any such challenge proceeding shall be on the 5 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 6 to harass or impose unnecessary expenses and burdens on other parties) may expose 7 the Challenging Party to sanctions. Unless the Designating Party has waived the 8 confidentiality designation by failing to file a motion to retain confidentiality as 9 described above, all parties shall continue to afford the material in question the level of 10 protection to which it is entitled under the Producing Party’s designation until the court 11 rules on the challenge. 12 7. 13 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 14 disclosed or produced by another Party or by a Non-Party in connection with this case 15 only for prosecuting, defending, or attempting to settle this litigation. Such Protected 16 Material may be disclosed only to the categories of persons and under the conditions 17 described in this Order. When the litigation has been terminated, a Receiving Party 18 must comply with the provisions of section 13 below (FINAL DISPOSITION). 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Order. 22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 23 ordered by the court or permitted in writing by the Designating Party, a Receiving 24 Party may disclose any information or item designated “CONFIDENTIAL” only to: 25 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 26 employees of said Outside Counsel of Record to whom it is reasonably necessary to 27 disclose the information for this litigation and who have signed the “Acknowledgment 28 and Agreement to Be Bound” that is attached hereto as Exhibit A; 8 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG (b) the officers, directors, and employees (including House Counsel) of the 1 2 Receiving Party to whom disclosure is reasonably necessary for this litigation and who 3 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 4 5 is reasonably necessary for this litigation and who have signed the “Acknowledgment 6 and Agreement to Be Bound” (Exhibit A); 7 (d) the court and its personnel; 8 (e) court reporters and their staff, professional jury or trial consultants, mock 9 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this 10 litigation and who have signed the “Acknowledgment and Agreement to Be Bound” 11 (Exhibit A); (f) during their depositions, witnesses in the action to whom disclosure is 12 13 reasonably necessary and who have signed the “Acknowledgment and Agreement to 14 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered 15 by the court. Pages of transcribed deposition testimony or exhibits to depositions that 16 reveal Protected Material must be separately bound by the court reporter and may not 17 be disclosed to anyone except as permitted under this Stipulated Protective Order. (g) the author or recipient of a document containing the information or a 18 19 custodian or other person who otherwise possessed or knew the information. 20 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 21 OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation that 23 compels disclosure of any information or items designated in this action as 24 “CONFIDENTIAL,” that Party must: 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 9 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG 1 order is subject to this Protective Order. Such notification shall include a copy of this 2 Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be pursued by 3 4 the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with 5 6 the subpoena or court order shall not produce any information designated in this action 7 as “CONFIDENTIAL” before a determination by the court from which the subpoena 8 or order issued, unless the Party has obtained the Designating Party’s permission. The 9 Designating Party shall bear the burden and expense of seeking protection in that court 10 of its confidential material – and nothing in these provisions should be construed as 11 authorizing or encouraging a Receiving Party in this action to disobey a lawful 12 directive from another court. 13 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 14 IN THIS LITIGATION 15 (a) The terms of this Order are applicable to information produced by a Non- 16 Party in this action and designated as “CONFIDENTIAL.” Such information produced 17 by Non-Parties in connection with this litigation is protected by the remedies and relief 18 provided by this Order. Nothing in these provisions should be construed as prohibiting 19 a Non-Party from seeking additional protections. 20 (b) In the event that a Party is required, by a valid discovery request, to produce 21 a Non-Party’s confidential information in its possession, and the Party is subject to an 22 agreement with the Non-Party not to produce the Non-Party’s confidential information, 23 then the Party shall: 24 (1) promptly notify in writing the Requesting Party and the Non-Party that 25 some or all of the information requested is subject to a confidentiality agreement with 26 a Non-Party; 27 28 10 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG 1 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 2 Order in this litigation, the relevant discovery request(s), and a reasonably specific 3 description of the information requested; and 4 (3) make the information requested available for inspection by the Non-Party. 5 (c) If the Non-Party fails to object or seek a protective order from this court 6 within 14 days of receiving the notice and accompanying information, the Receiving 7 Party may produce the Non-Party’s confidential information responsive to the 8 discovery request. If the Non-Party timely seeks a protective order, the Receiving 9 Party shall not produce any information in its possession or control that is subject to 10 the confidentiality agreement with the Non-Party before a determination by the court. 11 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 12 of seeking protection in this court of its Protected Material. 13 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 15 Protected Material to any person or in any circumstance not authorized under this 16 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 17 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 18 all unauthorized copies of the Protected Material, (c) inform the person or persons to 19 whom unauthorized disclosures were made of all the terms of this Order, and (d) 20 request such person or persons to execute the “Acknowledgment and Agreement to Be 21 Bound” that is attached hereto as Exhibit A. 22 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 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 protection, 26 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 27 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 28 may be established in an e-discovery order that provides for production without prior 11 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG 1 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 2 parties reach an agreement on the effect of disclosure of a communication or 3 information covered by the attorney-client privilege or work product protection, the 4 parties may incorporate their agreement in the stipulated protective order submitted to 5 the court. 6 12. 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 7 8 MISCELLANEOUS person to seek its modification by the court in the future. 12.2 Right to Assert Other Objections. By stipulating to the entry of this 9 10 Protective Order no Party waives any right it otherwise would have to object to 11 disclosing or producing any information or item on any ground not addressed in this 12 Stipulated Protective Order. Similarly, no Party waives any right to object on any 13 ground to use in evidence of any of the material covered by this Protective Order. 14 12.3 Filing Protected Material. Without written permission from the 15 Designating Party or a court order secured after appropriate notice to all interested 16 persons, a Party may not file in the public record in this action any Protected Material. 17 A Party that seeks to file under seal any Protected Material must comply with Civil 18 Local Rule 79-5. Protected Material may only be filed under seal pursuant to a court 19 order authorizing the sealing of the specific Protected Material at issue. Pursuant to 20 Civil Local Rule 79-5, a sealing order will issue only upon a request establishing that 21 the Protected Material at issue is privileged, protectable as a trade secret, or otherwise 22 entitled to protection under the law. If a Receiving Party's request to file Protected 23 Material under seal pursuant to Civil Local Rule 79-5(d) is denied by the court, then 24 the Receiving Party may file the information in the public record pursuant to Civil 25 Local Rule 79-5(e) unless otherwise instructed by the court. 26 13. 27 28 FINAL DISPOSITION Within 60 days after the final disposition of this action, as defined in paragraph 4, each Receiving Party must return all Protected Material to the Producing Party or 12 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG 1 destroy such material. As used in this subdivision, “all Protected Material” includes all 2 copies, abstracts, compilations, summaries, and any other format reproducing or 3 capturing any of the Protected Material. Whether the Protected Material is returned or 4 destroyed, the Receiving Party must submit a written certification to the Producing 5 Party (and, if not the same person or entity, to the Designating Party) by the 60 day 6 deadline that (1) identifies (by category, where appropriate) all the Protected Material 7 that was returned or destroyed and (2) affirms that the Receiving Party has not retained 8 any copies, abstracts, compilations, summaries or any other format reproducing or 9 capturing any of the Protected Material. Notwithstanding this provision, Counsel are 10 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and 11 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, 12 expert reports, attorney work product, and consultant and expert work product, even if 13 such materials contain Protected Material. Any such archival copies that contain or 14 constitute Protected Material remain subject to this Protective Order as set forth in 15 Section 4 (DURATION). 16 17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 18 19 Dated: April 18, 2017 By: /s/ Tina Wolfson Tina Wolfson Counsel for Plaintiff PAUL WRIGHT 20 21 22 23 AHDOOT & WOLFSON, PC Dated: April 18, 2017 JONES DAY By: /s/ Lee A. Armstrong Lee A. Armstrong Counsel for Defendant SIRIUS XM RADIO INC. 24 25 26 27 28 13 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG 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 5 have read in its entirety and understand the Stipulated Protective Order that was issued 6 by the United States District Court for the Central District of California on 7 _________________ [date] in the case of Wright v. Sirius XM Radio Inc., Case No. 8 8:16-cv-01688-JVS-JCG. I agree to comply with and to be bound by all the terms of 9 this Stipulated Protective Order and I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that is 12 subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 28 15 STIPULATED PROTECTIVE ORDER CASE NO. 8:16-cv-01688-JVS-JCG

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