Cristian Pascal et al v. Nissan North America, Inc.

Filing 71

STIPULATED PROTECTIVE ORDER 70 by Magistrate Judge John D. Early. (lom)

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1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 SOUTHERN DIVISION 11 12 13 CHRISTIAN PASCAL, et al., Plaintiffs, 14 15 vs. 16 NISSAN NORTH AMERICA, INC., 17 Defendant. 18 Case No. 8:20-cv-00492-JLS-JDE STIPULATED PROTECTIVE ORDER Judge: Honorable Josephine L. Staton Magistrate Judge: Hon. John D. Early Courtroom: 10A (Santa Ana) 19 20 Pursuant to the Stipulation and Proposed Protective Order lodged by Plaintiffs 21 22 23 24 25 26 27 28 Cristian Pascal and Maria Mengoni (“Plaintiffs”), Defendant Nissan North America, Inc. (“Defendant”), and third-party Nissan Motor Company, Limited (collectively “the parties”) on October 18, 2021 (Dkt. 70-1), and for good cause shown therein, the Court finds and orders as follows. 1. PURPOSES AND LIMITATIONS 1.1 Disclosure and discovery in this action may involve production of confidential, proprietary, or private information for which protection from public STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 1 disclosure and from use for any purpose other than pursuing this litigation may be 2 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the 3 following Stipulated Protective Order. The parties acknowledge that this Order does not 4 confer blanket protection on all disclosures or discovery and that the protection it affords 5 extends only to the information or items that are entitled to be treated as confidential 6 under the applicable legal principles. 7 1.2 The Parties agree to take care to limit any designation to specific material 8 that qualifies under the appropriate standards below. To the extent it is practical to do so, 9 the designating Party must designate for protection only those parts of the material, 10 11 documents, items, or oral or written communications that qualify. 1.3 Furthermore, the parties acknowledge that neither this Order nor any 12 confidentiality designation pursuant to it constitutes a ruling by this Court that any 13 specific information is, in fact, confidential. Nor does this Order, or any confidentiality 14 designation pursuant to it, entitle any party to file any information under seal. 15 1.4 Other than marking the document “CONFIDENTIAL” and making other 16 obvious redactions as appropriate, the Producing Party represents that the document is a 17 true and correct copy of the original. This designation will also encompass the following: 18 (1) any information copied or extracted from Covered Information; (2) all copies, 19 excerpts, summaries, or compilations of Covered Information; and (3) any out-of-court 20 testimony or presentations by Parties or their Counsel that reveals Covered Information. 21 2. CONFIDENTIAL INFORMATION 22 2.1 As used in this order, “Confidential Information” shall mean information or 23 tangible things for which there is good cause for confidentiality. Confidential Information 24 includes without limitation: technical data, trade secrets, know-how, research, product or 25 service ideas or plans, software codes and designs, algorithms, developments, inventions, 26 patent applications, laboratory notebooks, processes, formulas, techniques, mask works, 27 engineering designs and drawings, hardware configuration information, agreements with 28 third parties, lists of, or information relating to, employees and consultants including, but not limited to, the names, contact information, jobs, compensation, and expertise of such 1 STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 1 employees and consultants, lists of, or information relating to, suppliers and customers, 2 price lists, pricing methodologies, cost data, market share data, marketing plans, licenses, 3 contract information, business plans, financial forecasts, historical financial data, budgets 4 or any other confidential business or financial information, including, without limitation: 5 information regarding confidential business practices, or other confidential research, 6 development, or commercial information (including information implicating privacy 7 rights of third parties), information otherwise generally unavailable to the public, or 8 which may be privileged or otherwise protected from disclosure under state or federal 9 statutes, court rules, case decisions, or common law. “Confidential Information” does not 10 include any information that: 11 a. is publicly available at the time of disclosure; 12 b. becomes publicly available after disclosure through no fault of the Receiving 13 Party (defined below); 14 c. was known to the Receiving Party prior to disclosure; or 15 d. the Receiving Party lawfully receives at a later date from a third party 16 17 18 19 20 21 22 23 24 without restriction as to disclosure. 3. ADDITIONAL DEFINITIONS (a) Challenging Party: a Party that challenges a Designating Party’s confidentiality designation. (b) Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). (c) Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as 25 “CONFIDENTIAL.” The Party or Non -Party designating information or 26 items as confidential bear the burden of establishing good cause for the 27 confidentiality of all such information or items. 28 (d) Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, 2 STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 1 among other things, testimony, transcripts, and tangible things), that are 2 produced or generated in disclosures or responses to discovery. 3 (e) 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 5 serve as an expert witness, testifying or non-testifying, or as a consultant in 6 7 8 9 10 11 12 13 this Action, including any person specifically retained to provide expert opinions in a hybrid capacity. This definition includes consultants. Each such Expert, will agree to be bound by the terms of this Protective Order (f) 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. (g) Non-party: any natural person, partnership, corporation, association or other 14 legal entity not named as a Party to this action other than Nissan Motor 15 Company, Limited. 16 (h) Outside Counsel of Record: attorneys who are not employees of a party to 17 this Action but are retained to represent a party to this Action and have 18 appeared in this Action on behalf of that party or are affiliated with a law 19 firm that has appeared on behalf of that party, and includes support staff. 20 21 22 23 24 25 26 27 28 (i) Party: any party to this action, including all of its officers, directors, consultants, retained experts, and counsel (and their support staff). (j) Producing Party: a Party or Non-party that produces Disclosure or Discovery Material in this action. (k) Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors, or a professional jury or trial consultants retained in connection with this litigation. STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 3 1 (l) Protected Material: any Disclosure or Discovery Material that is designated 2 as “CONFIDENTIAL.” Unless the confidentiality designation is challenged 3 and (a) the Court decides such material is not entitled to protection as 4 confidential; or (c) the Designating Party withdraws it confidentiality 5 designation in writing. 6 (m) Receiving Party: a Party that receives Disclosure or Discovery Material from 7 8 9 a Producing Party 4. 4.1 SCOPE The protections conferred by this Stipulation and Order cover not only 10 Protected Material (as defined above), but also (1) any information copied or extracted 11 from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 12 13 14 15 16 17 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 5. DESIGNATING MATERIAL AS CONFIDENTIAL 19 5.1 Exercise of Restraint and Care in Designating Material for Protection: The 20 designation of material as confidential shall constitute a representation to the Court that 21 the Designating Party and its counsel believe in good faith that the information 22 constitutes Confidential Information. Parties and Non-Parties shall make a good faith 23 effort to designate information in a way that provides the greatest level of disclosure 24 possible, while still preserving the confidentiality of Confidential Information. Each Party 25 or Non-Party that designates information or items for protection under this Order must in 26 good faith take care to limit any such designation to specific material that qualifies under 27 the appropriate standards. The Designating Party must designate for protection only those 28 parts of material, documents, items or oral or written communications that qualify so that STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 4 1 other portions of the material, documents, items or communications for which protection 2 is not warranted are not swept unjustifiably within the ambit of this Order. 3 Mass, indiscriminate, or routinized designations are strictly prohibited. 4 Designations that are shown to be clearly unjustified or that have been made for an 5 improper purpose (e.g., to unnecessarily encumber or delay the case development 6 process, or to impose unnecessary expenses and burdens on other parties) may subject the 7 Designating Party to sanctions upon appropriate motion to the Court. 8 9 10 11 If it comes to a Designating Party’s attention that information that it designated confidential does not qualify for protection, that Designating Party must promptly notify all other parties that it is withdrawing the mistaken designation. 5.2 Manner and Timing of Designations. Except as otherwise provided in this 12 Order, or as otherwise stipulated or ordered, material that qualifies for protection under 13 this Order must be clearly designated confidential before the material is disclosed or 14 produced. 15 5.3 16 Designation in conformity with this Order requires: (a) For information in documentary form (e.g., paper or electronic 17 documents, but excluding transcripts of depositions or other pretrial or trial proceedings), 18 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 19 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 20 portion of the material on a page qualifies for protection, the Producing Party also must 21 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 22 margins). 23 A Party or Non-Party that makes original documents available for inspection need 24 not designate them for protection until after the inspecting Party has indicated which 25 documents it would like copied and produced. During the inspection and before the 26 designation, all of the material made available for inspection shall be deemed 27 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 28 copied and produced, the Producing Party must determine which documents, or portions thereof, qualify for protection under this Order. Then, before producing the specified 5 STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 1 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 2 that contains Protected Material. If only a portion of the material on a page qualifies for 3 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 4 by making appropriate markings in the margins). (b) 5 For testimony given in deposition proceedings, the Party or Non-party 6 offering or sponsoring the testimony must identify within thirty days of the receipt of the 7 transcript, all confidential testimony. 8 9 (c) For information produced in some form other than documentary and for any other tangible items, the Producing Party must affix in a prominent place on the 10 exterior of the container or containers in which the information or item is stored the 11 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants 12 protection, the Producing Party, to the extent practicable, shall identify the protected 13 portion(s) so as not to interfere with the viewing or use of the non-protected portions of 14 the evidence. 15 5.4 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 16 to designate information or items as confidential does not waive the Designating Party’s 17 right to secure protection under this Order for such material. Upon timely correction of a 18 designation, the Receiving Party must make reasonable efforts to assure that the material 19 is treated in accordance with the provisions of this Order. 20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 21 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 22 23 24 25 26 27 28 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37-1 et seq. 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint stipulation pursuant to Local Rule 37-2. 6.4 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 6 STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 1 Challenging Party to sanctions. Frivolous designations, and those made for an improper 2 purpose (e.g. to harass or impose unnecessary expenses and burdens on other parties) 3 may expose the Designating Party to sanctions. Unless the Designating Party has waived 4 or withdrawn the confidentiality designation, all parties shall continue to afford the 5 material in question the level of protection to which it is entitled under the Producing 6 Party’s designation until the Court rules on the challenge. 7 7. ACCESS TO AND USE OF PROTECTED MATERIAL 8 7.1 Basic Principles. A Receiving Party may use Protected Material that is 9 disclosed or produced by another Party or by a Non-Party in connection with this Action 10 only for prosecuting, defending or attempting to settle this Action. Such Protected 11 Material may be disclosed only to the categories of persons and under the conditions 12 described in this Order. When the Action has been terminated, a Receiving Party must 13 comply with the provisions of section 15 below (FINAL DISPOSITION). 14 Protected Material must be stored and maintained by a Receiving Party at a 15 location and in a secure manner that ensures that access is limited to the persons 16 authorized under this Order. 17 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 18 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 19 may disclose any information or item designated “CONFIDENTIAL” only to the 20 following Qualified Persons: 21 (a) The Receiving Party’s Outside Counsel of Record in this Action, as well 22 as employees of said Outside Counsel of Record to whom it is reasonably 23 necessary to disclose the information for this Action; 24 (b) 25 Receiving Party to whom disclosure is reasonably necessary for this 26 27 28 The officers, directors, and employees (including House Counsel) of the Action; (c) Experts (as defined in this Order) of the Receiving Party, including associated personnel necessary to assist Experts in these proceedings, such STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 7 1 as litigation assistants, paralegals, and secretarial and other clerical 2 personnel, so long as such Expert has signed the “Acknowledgment and 3 Agreement to Be Bound by Stipulated Protective Order” (Exhibit A); 4 (d) The Court and its personnel; 5 (e) Court reporters and their staff; (f) Professional jury or trial consultants, mock jurors, and Professional 6 7 Vendors to whom disclosure is reasonably necessary for this Action and 8 who have signed the “Acknowledgment and Agreement to Be Bound” 9 10 11 (Exhibit A); (g) custodian or other person who otherwise possessed or knew the 12 information; 13 14 The author or recipient of a document containing the information or a (h) Litigation support services, including outside copying services, court 15 reporters, stenographers, videographers, or companies engaged in the 16 business of supporting computerized or electronic litigation discovery or 17 trial preparation, retained by a Party or its counsel for the purpose of 18 assisting that Party in these proceedings, for whom a company 19 representative has signed the “Acknowledgment and Agreement to Be 20 Bound by Protective Order” (Exhibit A); 21 (i) Other Professional Vendors to whom disclosure is reasonably necessary 22 for this litigation and for whom a company representative has signed the 23 “Acknowledgment and Agreement to Be Bound by Stipulated Protective 24 Order” (Exhibit A); 25 26 27 28 (j) Actual or Potential Witness in the Action who has signed the “Acknowledgment and Agreement to Be Bound by Stipulated Protective Order” (Exhibit A), provided that counsel believes, in good faith, that STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 8 1 such disclosure is reasonably necessary for the prosecution or defense of 2 these proceedings; 3 (k) During their depositions, witnesses, and attorneys for witnesses, in the 4 Action to whom disclosure is reasonably necessary provided: (1) the 5 deposing party requests that the witness sign the form attached as Exhibit 6 A hereto; and (2) they will not be permitted to keep any confidential 7 information unless they sign the “Acknowledgment and Agreement to Be 8 Bound” (Exhibit A), unless otherwise agreed by the Designating Party or 9 ordered by the court. Pages of transcribed deposition testimony or exhibits 10 to depositions that reveal Protected Material may be separately bound by 11 the court reporter and may not be disclosed to anyone except as permitted 12 under this Stipulated Protective Order any mediator or arbitrator 13 14 appointed by the Court or selected by mutual agreement of the parties and 15 the mediator or arbitrator’s secretarial and clerical personnel, provided 16 that a company representative for the mediator or arbitrator has signed the 17 “Acknowledgment and Agreement to Be Bound by Stipulated Protective 18 Order” (Exhibit A); and (l) 19 20 mutually agreed upon by any of the parties engaged in settlement 21 22 23 24 25 26 27 28 any mediators or settlement officers and their supporting personnel, 8. discussions. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 8.1 If a Receiving Party is served with a subpoena or an order issued in other litigation that would compel disclosure of Protected Material, the Receiving Party must so notify the Designating Party in writing (by e-mail, if possible) within five (5) business days after receiving the subpoena or order. Such notification must include a copy of the subpoena or court order. STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 9 8.2 1 The Receiving Party also must promptly notify in writing the party that 2 caused the subpoena or order to issue that some or all the material covered by the 3 subpoena or order is the subject of this Protective Order. Such notification shall include a 4 copy of this Stipulated Protective Order. In addition, the Receiving Party must deliver a 5 copy of this Stipulated Protective Order promptly to the party in the other action that 6 caused the subpoena or order to issue. 8.3 7 The Receiving Party must also cooperate with respect to all reasonable 8 procedures sought to be pursued by the Designating Party whose Protected Material may 9 be affected. If the Designating Party timely asserts an objection, seeks a protective order 10 from the court where the subpoena or order issued, or otherwise requests that the Party 11 served with the subpoena or court order shall not produce any Protected Material before a 12 determination by that court, then the Party served with the subpoena or court order shall 13 not produce any Protected Material before a determination by that court, unless the Party 14 has obtained the Designating Party’s prior written permission. The Designating Party 15 shall bear the burden and expense of seeking protection in that court of its confidential 16 material—and nothing in these provisions should be construed as authorizing or 17 encouraging a Receiving Party in this action to disobey a lawful directive from another 18 court. 19 20 21 22 23 24 25 26 27 28 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 9.1 The terms of this Order are applicable to information produced by a Non- Party in this Action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in connection with this litigation is protected by the remedies and relief provided by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional protections. 9.2 In the event that a Party is required, by a discovery request, to produce a Non-Party’s confidential information in its possession, and the Party is subject to an agreement with the Non-Party not to produce the Non-Party’s confidential information, then the Party shall: STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 10 (1) promptly notify in writing the Requesting Party and the Non-Party that some or 1 2 all of the information requested is subject to a confidentiality agreement with a Non- 3 Party; 4 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order 5 in this Action, the relevant discovery request(s), and a reasonably specific description of 6 the information requested; and (3) make the information requested available for inspection by the Non-Party, if 7 8 requested. 9 9.3 If the Non-Party fails to seek a protective order from this court within 14 10 days of receiving the notice and accompanying information, the Receiving Party may 11 produce the Non-Party’s confidential information responsive to the discovery request. If 12 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 13 information in its possession or control that is subject to the confidentiality agreement 14 with the Non-Party before a determination by the court. Absent a court order to the 15 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 16 court of its Protected Material. 9.4 17 The provisions of this Section 9 set forth above do not apply to third-party 18 Nissan Motor Company, Limited. Nissan Motor Company, Limited is to be treated as a 19 “party” for the purposes of the application of this Protective Order. 20 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 21 10.1 If a Receiving Party learns that, by inadvertence or otherwise, it has 22 disclosed Protected Material to any person or in any circumstance not authorized under 23 this Stipulated Protective Order, the Receiving Party must promptly (a) notify in writing 24 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 25 all copies of the Protected Material, (c) inform the person or persons to whom 26 unauthorized disclosures were made of all the terms of this Order, and (d) request such 27 person or persons to execute the “Acknowledgment and Agreement to Be Bound by 28 Stipulated Protective Order” that is attached hereto as Exhibit A. /// STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 11 1 11. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 2 11.1 The parties acknowledge, that this Stipulated Protective Order does not 3 entitle them to file confidential information under seal; Local Civil Rule 79-5 sets forth 4 the procedures that must be followed and the standards that will be applied when a party 5 seeks permission from the court to file material under seal. Protected Material may only 6 be filed under seal pursuant to a court order authorizing the sealing of the specific 7 Protected Material. 8 12. FINAL DISPOSITION 9 12.1 After the final disposition of this Action, within 60 days of a written request 10 by the Designating Party, each Receiving Party must return all Protected Material to the 11 Producing Party or destroy such material. As used in this subdivision, “all Protected 12 Material” includes all copies, abstracts, compilations, summaries, and any other format 13 reproducing or capturing any of the Protected Material. Whether the Protected Material is 14 returned or destroyed, the Receiving Party must submit a written certification to the 15 Producing Party (and, if not the same person or entity, to the Designating Party) by the 16 60-day deadline that (1) identifies (by category, where appropriate) all the Protected 17 Material that was returned or destroyed and (2) affirms that the Receiving Party has not 18 retained any copies, abstracts, compilations, summaries or any other format reproducing 19 or capturing any of the Protected Material. Notwithstanding this provision, Counsel are 20 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and 21 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, 22 expert reports, attorney work product, and consultant and expert work product, even if 23 such materials contain Protected Material. Any such archival copies that contain or 24 constitute Protected Material remain subject to this Protective Order. 25 13. 26 13.1 Any violation of this Order may be punished by appropriate measures VIOLATIONS 27 including, without limitation, contempt proceedings and/or monetary sanctions. 28 /// STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 12 1 14. 2 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 3 MISCELLANEOUS person to seek its modification by the Court in the future. 4 14.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order, no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in this 7 Protective Order. Similarly, no Party waives any right to object on any ground to use in 8 evidence of any of the material covered by this Protective Order. 9 10 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 11 12 Dated: October 19, 2021 13 14 _______________________ JOHN D. EARLY United States Magistrate Judge 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 13 1 EXHIBIT A 2 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 3 4 5 Case No. 8:20-cv-00492-JLS-JDE CHRISTIAN PASCAL, et al., 6 EXHIBIT A TO STIPULATED PROTECTIVE ORDER Plaintiffs, 7 vs. 8 NISSAN NORTH AMERICA, INC., 9 Defendant. 10 Judge: Honorable Josephine L. Staton Magistrate Judge: Hon. John D. Early Courtroom: 10A (Santa Ana) 11 I acknowledge that I have read and understand the Stipulated Protective Order 12 entered in this action on ________________________________, 2020, and agree to 13 abide by its terms and conditions. Because it is necessary for me in the performance of 14 my duties to have access to Confidential Information that is the subject of the Stipulated 15 Protective Order, I understand and agree that I am personally bound by and subject to all 16 of the terms and provisions of this Order. 17 18 Date Signed: 19 20 Signature: 21 22 Name/Entity: 23 24 Address: 25 26 Email Address: 27 28 Telephone Number: STIPULATED PROTECTIVE ORDER Case No. 8:20-cv-00492-JLS-JDE 14

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