International, Inc. v. Ravindra Kumar Lahoti et al

Filing 38

STIPULATION AND PROTECTIVE ORDER by Magistrate Judge John D. Early (es)

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1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ) Case No. 8:17 cv 01614 JLS JDE INTERNATIONAL BRAVO.COM, ) ) INC., a Delaware corporation, ) STIPULATION AND ) PROTECTIVE ORDER Plaintiff, ) ) ) ) vs. ) ) ) RAVINDRA KUMAR LAHOTI, et ) ) al., ) ) ) Defendants. ) ) RAVINDRA KUMAR LAHOTI, an ) ) individual, ) Counterclaimant, ) ) ) v. ) ) LOUIE LARDAS, an individual, ) ) Counterdefendant. ) [Discovery Document: Referred to Magistrate Judge John D. Early] 1 2 1. 3 Discovery in this action is likely to involve production of confidential, PURPOSES AND LIMITATIONS 4 proprietary or private information for which special protection from public 5 disclosure and from use for any purpose other than pursuing this litigation may 6 be warranted. Accordingly, the parties hereby stipulate to and petition the 7 Court to enter the following Stipulated Protective Order. The parties 8 9 10 11 12 13 14 15 16 17 acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. 2. GOOD CAUSE STATEMENT This action is likely to involve sensitive personal, commercial, financial, technical and/or proprietary information for which special protection from public disclosure and from use for any purpose other than prosecution of this action is warranted. Such confidential and proprietary materials and 18 information consist of, among other things, personal emails, user account 19 information and passwords to various domain name, business and/or financial 20 accounts, confidential business or financial information, information regarding 21 confidential business practices, or other sensitive personal or commercial 22 information (including information implicating privacy rights of third parties), 23 information otherwise generally unavailable to the public, or which may be 24 privileged or otherwise protected from disclosure under state or federal 25 statutes, court rules, case decisions, or common law. Accordingly, to expedite 26 the flow of information, to facilitate the prompt resolution of disputes over 27 confidentiality of discovery materials, to adequately protect information the 28 parties are entitled to keep confidential, to ensure that the parties are permitted 2 1 reasonable necessary uses of such material in preparation for and in the 2 conduct of trial, to address their handling at the end of the litigation, and serve 3 the ends of justice, a protective order for such information is justified in this 4 matter. It is the intent of the parties that information will not be designated as 5 confidential for tactical reasons and that nothing be so designated without a 6 good faith belief that it has been maintained in a confidential, non-public 7 manner, and there is good cause why it should not be part of the public record 8 9 10 11 12 13 14 15 16 17 of this case. 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle them to file confidential information under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the standards that will be applied when a party seeks permission from the court to file material under seal. There is a strong presumption that the public has a right of access to judicial proceedings and 18 records in civil cases. In connection with non-dispositive motions, good cause 19 must be shown to support a filing under seal. See Kamakana v. City and 20 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. 21 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony 22 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 23 protective orders require good cause showing), and a specific showing of good 24 cause or compelling reasons with proper evidentiary support and legal 25 justification, must be made with respect to Protected Material that a party 26 seeks to file under seal. The parties’ mere designation of Disclosure or 27 Discovery Material as CONFIDENTIAL does not— without the submission 28 of competent evidence by declaration, establishing that the material sought to 3 1 be filed under seal qualifies as confidential, privileged, or otherwise 2 protectable—constitute good cause. 3 Further, if a party requests sealing related to a dispositive motion or trial, 4 then compelling reasons, not only good cause, for the sealing must be shown, 5 and the relief sought shall be narrowly tailored to serve the specific interest to 6 be protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th 7 Cir. 2010). For each item or type of information, document, or thing sought to 8 9 10 11 12 13 14 15 16 17 be filed or introduced under seal, the party seeking protection must articulate compelling reasons, supported by specific facts and legal justification, for the requested sealing order. Again, competent evidence supporting the application to file documents under seal must be provided by declaration. Any document that is not confidential, privileged, or otherwise protectable in its entirety will not be filed under seal if the confidential portions can be redacted. If documents can be redacted, then a redacted version for public viewing, omitting only the confidential, privileged, or otherwise protectable portions of the document, shall be filed. Any application that seeks 18 to file documents under seal in their entirety should include an explanation of 19 why redaction is not feasible. 20 4. DEFINITIONS 21 4.1 Action: this pending federal lawsuit. 22 4.2 Challenging Party: a Party or Non-Party that challenges the 23 24 designation of information or items under this Order. 4.3 “CONFIDENTIAL” Information or Items: information 25 (regardless of how it is generated, stored or maintained) or tangible things that 26 qualify for protection under Federal Rule of Civil Procedure 26(c), and as 27 specified above in the Good Cause Statement. 28 4 1 2 3 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 4.5 Designating Party: a Party or Non-Party that designates 4 information or items that it produces in disclosures or in responses to discovery 5 as “CONFIDENTIAL.” 6 7 8 9 10 11 12 13 14 15 16 17 18 19 4.6 Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery. 4.7 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this Action. 4.8 House Counsel: attorneys who are employees of a party to this Action. House Counsel does not include Outside Counsel of Record or any other outside counsel. 4.9 Non-Party: any natural person, partnership, corporation, association or other legal entity not named as a Party to this action. 4.10 Outside Counsel of Record: attorneys who are not employees of a 20 party to this Action but are retained to represent a party to this Action and 21 have appeared in this Action on behalf of that party or are affiliated with a law 22 firm that has appeared on behalf of that party, and includes support staff. 23 4.11 Party: any party to this Action, including all of its officers, 24 directors, employees, consultants, retained experts, and Outside Counsel of 25 Record (and their support staffs). 26 27 28 4.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 4.13 Professional Vendors: persons or entities that provide litigation 5 1 support services (e.g., photocopying, videotaping, translating, preparing 2 exhibits or demonstrations, and organizing, storing, or retrieving data in any 3 form or medium) and their employees and subcontractors. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 4.14 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party. 5. SCOPE The protections conferred by this Stipulation and Order cover not only Protected Material (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the trial judge and other applicable authorities. This Order does not govern the use of Protected Material at trial. 18 6. DURATION 19 Once a case proceeds to trial, information that was designated as 20 CONFIDENTIAL or maintained pursuant to this protective order used or 21 introduced as an exhibit at trial becomes public and will be presumptively 22 available to all members of the public, including the press, unless compelling 23 reasons supported by specific factual findings to proceed otherwise are made to 24 the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 25 (distinguishing “good cause” showing for sealing documents produced in 26 discovery from “compelling reasons” standard when merits-related documents 27 are part of court record). Accordingly, the terms of this protective order do not 28 extend beyond the commencement of the trial. 6 1 7. DESIGNATING PROTECTED MATERIAL 2 7.1 Exercise of Restraint and Care in Designating Material for 3 Protection. Each Party or Non-Party that designates information 4 or items for protection under this Order must take care to limit any such 5 designation to specific material that qualifies under the appropriate standards. 6 The Designating Party must designate for protection only those parts of 7 material, documents, items or oral or written communications that qualify so 8 9 10 11 12 13 14 15 16 17 that other portions of the material, documents, items or communications for which protection is not warranted are not swept unjustifiably within the ambit of this Order. 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 expose the Designating Party to sanctions. If it comes to a Designating Party’s attention that information or items 18 that it designated for protection do not qualify for protection, that Designating 19 Party must promptly notify all other Parties that it is withdrawing the 20 inapplicable designation. 21 7.2 Manner and Timing of Designations. Except as otherwise 22 provided in this Order, or as otherwise stipulated or ordered, Disclosure of 23 Discovery Material that qualifies for protection under this Order must be 24 clearly so designated before the material is disclosed or produced. 25 26 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 27 documents, but excluding transcripts of depositions or other pretrial or trial 28 proceedings), that the Producing Party affix at a minimum, the legend 7 1 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page 2 that contains protected material. If only a portion of the material on a page 3 qualifies for protection, the Producing Party also must clearly identify the 4 protected portion(s) (e.g., by making appropriate markings in the margins). 5 A Party or Non-Party that makes original documents available for 6 inspection need not designate them for protection until after the inspecting 7 Party has indicated which documents it would like copied and produced. 8 9 10 11 12 13 14 15 16 17 During the inspection and before the designation, all of the material made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants copied and produced, the Producing Party must determine which documents, or portions thereof, qualify for protection under this Order. Then, before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page that contains Protected Material. If only a portion of the material on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). (b) for testimony given in depositions that the Designating Party 18 19 identifies the Disclosure or Discovery Material on the record, before the close 20 of the deposition all protected testimony. 21 (c) for information produced in some form other than 22 documentary and for any other tangible items, that the Producing Party affix 23 in a prominent place on the exterior of the container or containers in which the 24 information is stored the legend “CONFIDENTIAL.” If only a portion or 25 portions of the information warrants protection, the Producing Party, to the 26 extent practicable, shall identify the protected portion(s). 27 28 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate qualified information or items does not, 8 1 standing alone, waive the Designating Party’s right to secure protection under 2 this Order for such material. Upon timely correction of a designation, the 3 Receiving Party must make reasonable efforts to assure that the material is 4 treated in accordance with the provisions of this Order. 5 8. 6 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 7 8 9 10 11 12 13 14 15 16 17 CHALLENGING CONFIDENTIALITY DESIGNATIONS designation of confidentiality at any time that is consistent with the Court’s Scheduling Order. 8.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37-1 et seq. 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint stipulation pursuant to Local Rule 37-2. 8.4 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 18 Designating Party has waived or withdrawn the confidentiality designation, all 19 parties shall continue to afford the material in question the level of protection 20 to which it is entitled under the Producing Party’s designation until the Court 21 rules on the challenge. 22 23 24 25 26 27 28 9. ACCESS TO AND USE OF PROTECTED MATERIAL 9.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or produced by another Party or by a Non-Party in connection with this Action only for prosecuting, defending or attempting to settle this Action. Such Protected Material may be disclosed only to the categories of persons and under the conditions described in this Order. When the Action has 9 1 been terminated, a Receiving Party must comply with the provisions of section 2 15 below (FINAL DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party 4 at a location and in a secure manner that ensures that access is limited to the 5 persons authorized under this Order. 6 7 8 9 10 11 12 13 14 15 16 17 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any information or item designated “CONFIDENTIAL” only to: (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this Action; (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; (c) Experts (as defined in this Order) of the Receiving Party to 18 whom disclosure is reasonably necessary for this Action and who have signed 19 the “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 23 Professional Vendors to whom disclosure is reasonably necessary for this 24 Action and who have signed the “Acknowledgment and Agreement to Be 25 Bound” (Exhibit A); 26 (g) the author or recipient of a document containing the 27 information or a custodian or other person who otherwise possessed or knew 28 the information; 10 (h) during their depositions, witnesses, and attorneys for witnesses, 1 2 in the Action to whom disclosure is reasonably necessary provided: (1) the 3 deposing party requests that the witness sign the form attached as Exhibit A 4 hereto; and (2) they will not be permitted to keep any confidential information 5 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit 6 A), unless otherwise agreed by the Designating Party or ordered by the court. 7 Pages of transcribed deposition testimony or exhibits to depositions that reveal 8 9 10 11 12 13 14 15 Protected Material may be separately bound by the court reporter and may not be disclosed to anyone except as permitted under this Stipulated Protective Order; and (i) any mediators or settlement officers and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 16 17 If a Party is served with a subpoena or a court order issued in other 18 litigation that compels disclosure of any information or items designated in this 19 Action as “CONFIDENTIAL,” that Party must: 20 21 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; 22 (b) promptly notify in writing the party who caused the subpoena 23 or order to issue in the other litigation that some or all of the material covered 24 by the subpoena or order is subject to this Protective Order. Such notification 25 shall include a copy of this Stipulated Protective Order; and 26 (c) cooperate with respect to all reasonable procedures sought to be 27 pursued by the Designating Party whose Protected Material may be affected. If 28 the Designating Party timely seeks a protective order, the Party served with the 11 1 subpoena or court order shall not produce any information designated in this 2 action as “CONFIDENTIAL” before a determination by the court from which 3 the subpoena or order issued, unless the Party has obtained the Designating 4 Party’s permission. The Designating Party shall bear the burden and expense 5 of seeking protection in that court of its confidential material and nothing in 6 these provisions should be construed as authorizing or encouraging a 7 Receiving Party in this Action to disobey a lawful directive from another court. 8 9 10 11 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION (a) The terms of this Order are applicable to information produced 12 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 13 information produced by Non-Parties in connection with this litigation is 14 protected by the remedies and relief provided by this Order. Nothing in these 15 provisions should be construed as prohibiting a Non-Party from seeking 16 additional protections. 17 (b) In the event that a Party is required, by a valid discovery 18 request, to produce a Non-Party’s confidential information in its possession, 19 and the Party is subject to an agreement with the Non-Party not to produce the 20 Non-Party’s confidential information, then the Party shall: 21 22 23 24 25 26 27 28 (1) promptly notify in writing the Requesting Party and the NonParty that some or all of the information requested is subject to a confidentiality agreement with a Non-Party; (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in this Action, the relevant discovery request(s), and a reasonably specific description of the information requested; and (3) make the information requested available for inspection by the 12 1 Non-Party, if requested. 2 (c) If the Non-Party fails to seek a protective order from this court 3 within 14 days of receiving the notice and accompanying information, the 4 Receiving Party may produce the Non-Party’s confidential information 5 responsive to the discovery request. If the Non-Party timely seeks a protective 6 order, the Receiving Party shall not produce any information in its possession 7 or control that is subject to the confidentiality agreement with the Non-Party 8 9 10 11 12 13 14 15 16 17 before a determination by the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of seeking protection in this court of its Protected Material. 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected Material to any person or in any circumstance not authorized under this Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized 18 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 19 Protected Material, (c) inform the person or persons to whom unauthorized 20 disclosures were made of all the terms of this Order, and (d) request such 21 person or persons to execute the “Acknowledgment an Agreement to Be 22 Bound” attached hereto as Exhibit A. 23 24 25 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL When a Producing Party gives notice to Receiving Parties that certain 26 inadvertently produced material is subject to a claim of privilege or other 27 protection, the obligations of the Receiving Parties are those set forth in 28 Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to 13 1 modify whatever procedure may be established in an e-discovery order that 2 provides for production without prior privilege review. The production of 3 privileged or work-product protected documents, electronically stored 4 information (“ESI”) or information, whether inadvertent or otherwise, is not a 5 waiver of the privilege or protection from discovery in this Action or in any 6 other federal or state proceeding. This Order shall be interpreted to provide the 7 maximum protection allowed by Federal Rule of Evidence 502(d) and (e). 8 9 10 11 12 13 14 15 16 17 Nothing contained herein is intended or shall serve to limit a Party’s right to conduct a review of documents, ESI or information (including metadata) for relevance, responsiveness, and/or segregation of privileged and/or protected information before production. 14. MISCELLANEOUS 14.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the Court in the future. 14.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order, no Party waives any right it otherwise would have to object 18 to disclosing or producing any information or item on any ground not 19 addressed in this Stipulated Protective Order. Similarly, no Party waives any 20 right to object on any ground to use in evidence of any of the material covered 21 by this Protective Order. 22 14.3 Filing Protected Material. A Party that seeks to file under seal any 23 Protected Material must comply with Local Civil Rule 79-5. Protected 24 Material may only be filed under seal pursuant to a court order authorizing the 25 sealing of the specific Protected Material. If a Party’s request to file Protected 26 Material under seal is denied by the court, then the Receiving Party may file 27 the information in the public record unless otherwise instructed by the court. 28 15. FINAL DISPOSITION 14 1 After the final disposition of this Action, as defined in paragraph 6, 2 within 60 days of a written request by the Designating Party, each Receiving 3 Party must return all Protected Material to the Producing Party or destroy such 4 material. As used in this subdivision, “all Protected Material” includes all 5 copies, abstracts, compilations, summaries, and any other format reproducing 6 or capturing any of the Protected Material. Whether the Protected Material is 7 returned or destroyed, the Receiving Party must submit a written certification 8 9 10 11 12 13 14 15 16 17 to the Producing Party (and, if not the same person or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by category, where appropriate) all the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant and expert 18 work product, even if such materials contain Protected Material. Any such 19 archival copies that contain or constitute Protected Material remain subject to 20 this Protective Order as set forth in Section 6 (DURATION). 21 16. VIOLATION 22 Any violation of this Order may be punished by appropriate measures 23 including, without limitation, contempt proceedings and/or monetary 24 sanctions. 25 26 27 28 15 1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 4 DATED: February 8, 2017 /s/ Brett Lewis______________________ Attorneys for Plaintiff DATED: February 8, 2017 /s/ Jacob C. Gonzales________________ Attorneys for Defendant 5 6 7 8 9 10 11 I, Brett Lewis, am the CM/ECF user whose ID and password are being used to file this Stipulation and Proposed Protective Order. Pursuant to Local Civil Rule 5-4.3.4(a)(2)(i), I hereby attest that Jacob C. Gonzales, on whose behalf this filing is jointly submitted, has concurred in this filing. 12 13 /s/ Brett Lewis____________ 14 Brett Lewis 15 16 17 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 18 19 20 February 8, 2018 DATED: _________________ 21 22 23 ________________________ _ _ _________________________________ OHN JOHN D. EARLY United States Magistrate Judge 24 25 26 27 28 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT A 1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 ) Case No. 8:17 cv 01614 JLS JDE ) INTERNATIONAL BRAVO.COM, ) INC., a Delaware corporation, ) ACKNOWLEDGMENT AND ) AGREEMENT TO BE BOUND Plaintiff, ) ) ) ) vs. ) ) ) RAVINDRA KUMAR LAHOTI, et ) ) al., ) ) ) Defendants. ) ) RAVINDRA KUMAR LAHOTI, an ) ) individual, ) Counterclaimant, ) ) ) v. ) ) LOUIE LARDAS, an individual, ) ) Counterdefendant. ) 19 20 21 22 23 24 25 26 27 28 I, ______________________________, state that: 1. My address is __________________________________________________. 2. I have received a copy of the Stipulation and Protective Order (the “Order”) entered in the above-captioned action (the “Action”). 3. I have carefully read the Order and I understand its provisions. Acknowledgment and Agreement to Be Bound 1 2 3 4. I will comply with the Order. 5. I will hold in confidence and will not disclose to anyone other than those 4 qualified under the Order, any Protected Material that is produced or 5 disclosed to me. 6 7 8 9 10 6. To the extent Protected Material is disclosed to me, it will be used only for purposes of this Action. 7. At the conclusion of this Action, I will return all Protected Material, and 11 documents and things that I have prepared relating thereto, to counsel for the 12 party by whom I am employed or retained, or to counsel from whom I 13 14 15 16 received the Protected Material. Signed: ______________________________ 17 18 Date: 19 ______________________________ 20 21 22 23 24 25 26 27 28 Acknowledgment and Agreement to Be Bound

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