G and H Diversified Manufacturing LP v. Regreen Technologies, Inc. et al

Filing 25

PROTECTIVE ORDER by Magistrate Judge John D. Early re Stipulation for Protective Order 24 . (see document for details) (hr)

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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 14 Case No.: 8:21-cv-00062-CJC-JDEx G&H DIVERSIFIED MANUFACTURING LP, a Texas limited STIPULATED PROTECTIVE ORDER partnership 15 16 17 18 19 20 21 22 Plaintiff, vs. REGREEN TECHNOLOGIES, INC. f/k/a Regreen International Solutions, Inc., a California corporation, ALBERT AVEDIS MARDIKIAN, an individual; and DOES 1 through 10, inclusive, Defendants. Action Filed: January 12, 2021 Trial Date: February 28, 2022 23 24 25 26 27 28 ____________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 1 1 2 BASED UPON THE STIPULATION OF THE PARTIES, AND GOOD CAUSE APPEARING, IT IS HEREBY ORDERED as follows: 3 1. 4 Discovery in this action is likely to involve production of confidential, proprietary 5 6 7 8 9 10 11 12 13 14 PURPOSES AND LIMITATIONS or private information for which special protection from public disclosure and from use for any purpose other than pursuing this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties 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 There is good cause to support this Order. Namely, the parties to this action are 15 involved in the manufacture of waste systems machinery. This Acton involves acts of the 16 parties under a contract for the manufacture of this machinery, which involves trade 17 secrets, confidential customer and vendor lists and communications, and other 18 confidential business information. 19 This action is likely to involve trade secrets, customer and pricing lists and other 20 valuable research, development, commercial, financial, technical and/or proprietary 21 information for which special protection from public disclosure and from use for any 22 purpose other than prosecution of this action is warranted. Such confidential and 23 proprietary materials and information consist of, among other things, confidential 24 business or financial information, information regarding confidential business practices, 25 26 27 28 or other confidential research, development, or commercial information (including information implicating privacy rights of third parties), information otherwise generally unavailable to the public, or which may be privileged or otherwise protected from ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 2 1 disclosure under state or federal statutes, court rules, case decisions, or common law. 2 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 3 disputes over confidentiality of discovery materials, to adequately protect information the 4 parties are entitled to keep confidential, to ensure that the parties are permitted reasonable 5 necessary uses of such material in preparation for and in the conduct of trial, to address 6 7 8 9 10 11 12 13 14 their handling at the end of the litigation, and serve the ends of justice, a protective order for such information is justified in this matter. It is the intent of the parties that information will not be designated as confidential for tactical reasons and that nothing be so designated without a good faith belief that it has been maintained in a confidential, non-public manner, and there is good cause why it should not be part of the public record of this case. 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE The parties further acknowledge, as set forth in Section 14.3, below, that this 15 Stipulated Protective Order does not entitle them to file confidential information under 16 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 17 standards that will be applied when a party seeks permission from the court to file 18 material under seal. There is a strong presumption that the public has a right of access to 19 judicial proceedings and records in civil cases. In connection with non-dispositive 20 motions, good cause must be shown to support a filing under seal. See Kamakana v. City 21 and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 22 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 23 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 24 cause showing), and a specific showing of good cause or compelling reasons with proper 25 26 27 28 evidentiary support and legal justification, must be made with respect to Protected Material that a party seeks to file under seal. The parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL does not— without the submission of ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 3 1 competent evidence by declaration, establishing that the material sought to be filed under 2 seal qualifies as confidential, privileged, or otherwise protectable—constitute good cause. 3 Further, if a party requests sealing related to a dispositive motion or trial, then 4 compelling reasons, not only good cause, for the sealing must be shown, and the relief 5 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 6 7 8 9 10 11 12 13 v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type of information, document, or thing sought to 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 14 be redacted, then a redacted version for public viewing, omitting only the confidential, 15 privileged, or otherwise protectable portions of the document, shall be filed. Any 16 application that seeks to file documents under seal in their entirety should include an 17 explanation of why redaction is not feasible. 18 4. 19 4.1 Action: This instant lawsuit with Case Number 8:21-cv-00062- CJC (JDEx) 20 21 22 23 24 25 26 27 28 DEFINITIONS that is pending in this Court. 4.2 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 4.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause Statement. ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 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 information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 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 party to this 18 Action but are retained to represent a party to this Action and have appeared in this 19 Action on behalf of that party or are affiliated with a law firm that has appeared on behalf 20 of that party, and includes support staff. 21 4.11 Party: any party to this Action, including all of its officers, directors, 22 employees, consultants, retained experts, and Outside Counsel of Record (and their 23 support staffs). 24 25 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 support services (e.g., photocopying, videotaping, translating, preparing exhibits or ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 5 1 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 2 their employees and subcontractors. 3 4 5 6 7 8 9 10 11 12 13 14 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 15 judge and other applicable authorities. This Order does not govern the use of Protected 16 Material at trial. 17 6. 18 Once a case proceeds to trial, information that was designated as DURATION 19 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as 20 an exhibit at trial becomes public and will be presumptively available to all members of 21 the public, including the press, unless compelling reasons supported by specific factual 22 findings to proceed otherwise are made to the trial judge in advance of the trial. See 23 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing 24 documents produced in discovery from “compelling reasons” standard when merits- 25 26 27 28 related documents are part of court record). Accordingly, the terms of this protective order do not extend beyond the commencement of the trial. ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 6 1 7. DESIGNATING PROTECTED MATERIAL 2 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each 3 Party or Non-Party that designates information or items for protection under this Order 4 must take care to limit any such designation to specific material that qualifies under the 5 appropriate standards. The Designating Party must designate for protection only those 6 7 8 9 10 11 12 13 parts of material, documents, items or oral or written communications that qualify so 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. 14 If it comes to a Designating Party’s attention that information or items that it 15 designated for protection do not qualify for protection, that Designating Party must 16 promptly notify all other Parties that it is withdrawing the inapplicable designation. 17 7.2 Manner and Timing of Designations. Except as otherwise provided in this 18 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that 19 qualifies for protection under this Order must be clearly so designated before the material 20 is disclosed or produced. 21 22 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 23 documents, but excluding transcripts of depositions or other pretrial or trial proceedings), 24 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 25 26 27 28 “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 ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 7 1 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 2 margins). 3 A Party or Non-Party that makes original documents available for inspection need 4 not designate them for protection until after the inspecting Party has indicated which 5 documents it would like copied and produced. During the inspection and before the 6 7 8 9 10 11 12 13 14 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 identifies 15 16 the Disclosure or Discovery Material on the record, before the close of the deposition all 17 protected testimony. (c) for information produced in some form other than documentary and for 18 19 any other tangible items, that the Producing Party affix in a prominent place on the 20 exterior of the container or containers in which the information is stored the legend 21 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 22 the Producing Party, to the extent practicable, shall identify the protected portion(s). 23 24 25 26 27 28 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate qualified information or items does not, standing alone, waive the Designating Party’s right to secure protection under this Order for such material. Upon timely correction of a designation, the Receiving Party must make reasonable efforts to assure that the material is treated in accordance with the provisions of this Order. ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 8 1 8. 2 8.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 3 4 5 6 7 8 9 10 11 12 13 CHALLENGING CONFIDENTIALITY DESIGNATIONS 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 Designating Party has waived or withdrawn the confidentiality designation, all parties shall continue to afford the material in question 14 the level of protection to which it is entitled under the Producing Party’s designation until 15 the Court rules on the challenge. 16 9. 17 9.1 Basic Principles. A Receiving Party may use Protected Material that is 18 disclosed or produced by another Party or by a Non-Party in connection with this Action 19 only for prosecuting, defending or attempting to settle this Action. Such Protected 20 Material may be disclosed only to the categories of persons and under the conditions 21 described in this Order. When the Action has been terminated, a Receiving Party must 22 comply with the provisions of section 15 below (FINAL DISPOSITION). 23 24 25 ACCESS TO AND USE OF PROTECTED MATERIAL Protected Material must be stored and maintained by a Receiving Party at a location and in a secure manner that ensures that access is limited to the persons authorized under this Order. 26 27 28 ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 9 1 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 2 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 3 may disclose any information or item designated 4 “CONFIDENTIAL” only to: 5 6 7 8 9 10 11 12 13 (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 whom disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement to Be Bound” (See Exhibit A attached to this 14 STIPULATION AND PROPOSED ORDER for a copy of this Acknowledgment and 15 Agreement to Be Bound); 16 (d) the court and its personnel; 17 (e) court reporters and their staff; 18 (f) professional jury or trial consultants, mock jurors, and Professional 19 Vendors to whom disclosure is reasonably necessary for this Action and who have signed 20 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 22 23 24 25 26 27 28 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; (h) during their depositions, witnesses, and attorneys for witnesses, in the Action to whom disclosure is reasonably necessary provided: (1) the deposing party requests that the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted to keep any confidential information unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 10 1 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to 2 depositions that reveal Protected Material may be separately bound by the court reporter 3 and may not be disclosed to anyone except as permitted under this Stipulated Protective 4 Order; and 5 6 7 8 9 10 11 12 13 14 15 (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 If a Party is served with a subpoena or a court order issued in other litigation that compels disclosure of any information or items designated in this Action as “CONFIDENTIAL,” that Party must: (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 16 issue in the other litigation that some or all of the material covered by the subpoena or 17 order is subject to this Protective Order. Such notification shall include a copy of this 18 Stipulated Protective Order; and 19 (c) cooperate with respect to all reasonable procedures sought to be pursued 20 by the Designating Party whose Protected Material may be affected. If the Designating 21 Party timely seeks a protective order, the Party served with the subpoena or court order 22 shall not produce any information designated in this action as “CONFIDENTIAL” before 23 a determination by the court from which the subpoena or order issued, unless the Party 24 has obtained the Designating Party’s permission. The Designating Party shall bear the 25 26 27 28 burden and expense of seeking protection in that court of its confidential material and nothing in these provisions should be construed as authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive from another court. ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 11 1 11. 2 BE PRODUCED IN THIS LITIGATION 3 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO (a) The terms of this Order are applicable to information produced by a Non- 4 Party in this Action and designated as “CONFIDENTIAL.” Such information produced 5 by Non-Parties in connection with this litigation is protected by the remedies and relief 6 7 8 9 10 11 12 provided by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional protections. (b) In the event that a Party is required, by a valid 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: (1) promptly notify in writing the Requesting Party and the Non-Party that 13 14 some or all of the information requested is subject to a confidentiality agreement with a 15 Non-Party; 16 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 17 Order in this Action, the relevant discovery request(s), and a reasonably specific 18 description of the information requested; and 19 20 21 (3) make the information requested available for inspection by the NonParty, if requested. (c) If the Non-Party fails to seek a protective order from this court within 14 22 days of receiving the notice and accompanying information, the Receiving Party may 23 produce the Non-Party’s confidential information responsive to the discovery request. If 24 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 25 26 27 28 information in its possession or control that is subject to the confidentiality agreement with the Non-Party before a determination by the court. Absent a court order to the ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 12 1 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 2 court of its Protected Material. 3 12. 4 MATERIAL 5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 6 7 8 9 10 11 12 13 UNAUTHORIZED DISCLOSURE OF PROTECTED 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 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the terms of this Order, and (d) request such person or persons to execute the “Acknowledgment an Agreement to Be Bound” attached hereto as Exhibit A. 14 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 15 PROTECTED MATERIAL 16 When a Producing Party gives notice to Receiving Parties that certain inadvertently 17 produced material is subject to a claim of privilege or other protection, the obligations of 18 the Receiving Parties are those set forth in Federal Rule of Civil\ Procedure 26(b)(5)(B). 19 This provision is not intended to modify whatever procedure may be established in an e- 20 discovery order that provides for production without prior privilege review. Pursuant to 21 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 22 effect of disclosure of a communication or information covered by the attorney-client 23 privilege or work product protection, the parties may incorporate their agreement in the 24 stipulated protective order submitted to the court. 25 26 27 28 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. ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 13 1 14.2 Right to Assert Other Objections. By stipulating to the entry of this 2 Protective Order, no Party waives any right it otherwise would have to object to 3 disclosing or producing any information or item on any ground not addressed in this 4 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground 5 to use in evidence of any of the material covered by this Protective Order. 6 7 8 9 10 11 12 13 14 14.3 Filing Protected Material. A Party that seeks to file under seal any Protected Material must comply with Local Civil Rule 79-5. Protected Material may only be filed under seal pursuant to a court order authorizing the sealing of the specific Protected Material. If a Party’s request to file Protected Material under seal is denied by the court, then the Receiving Party may file the information in the public record unless otherwise instructed by the court. 15. FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 6, within 60 days 15 of a written request by the Designating Party, each Receiving Party must return all 16 Protected Material to the Producing Party or destroy such material. As used in this 17 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 18 summaries, and any other format reproducing or capturing any of the Protected Material. 19 Whether the Protected Material is returned or destroyed, the Receiving Party must submit 20 a written certification to the Producing Party (and, if not the same person or entity, to the 21 Designating Party) by the 60-day deadline that (1) identifies (by category, where 22 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 23 the Receiving Party has not retained any copies, abstracts, compilations, summaries or 24 any other format reproducing or capturing any of the Protected Material. 25 26 27 28 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 ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 14 1 consultant and expert work product, even if such materials contain Protected Material. 2 Any such archival copies that contain or constitute Protected Material remain subject to 3 this Protective Order as set forth in Section 6 (DURATION). 4 16. 5 Any violation of this Order may be punished by appropriate measures including, 6 7 8 9 10 VIOLATION without limitation, contempt proceedings and/or monetary sanctions. IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. June 2, 2021 by: KINSELLA WEITZMAN ISEER KUMP LLP By: /s/ Nicholas Soltman Nicholas Soltman, Esq. Attorney for Plaintiff G&H Diversified Manufacturing LP 11 12 13 14 15 June 2, 2021 by: MADISON LAW, APC By: /s/ Dixon Gardner Dixon Gardner, Esq. Attorney for Defendants Regreen Technologies, Inc. and Albert Avedis Mardikian 16 17 18 19 20 21 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 22 23 DATED: June 3, 2021 24 25 26 _________________________________ JOHN D. EARLY United States Magistrate Judge 27 28 ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 15 1 EXHIBIT A 2 Acknowledgment and Agreement to Be Bound 3 4 5 6 7 8 9 10 11 12 13 14 The undersigned hereby acknowledges that he/she has read the PROTECTIVE ORDER which was entered by the Court on June 3, 2021 in G&H Diversified Manufacturing LP v. Regreen Technologies, Inc., et al., Case No. 8:21-cv-00062-CJCJDE, that he/she is one of the persons contemplated in paragraphs 4 and 5 thereof as authorized to receive disclosure of Disclosure or Discovery Material designated CONFIDENTIAL by any of the parties or by third parties, and that he/she fully understand and agrees to abide by the obligations and conditions of the Protective Order. The undersigned further consents to be subject to the jurisdiction of the United States District Court for the Central District of California for purposes of any proceedings relating to performance under, compliance with or violation of the above-described Order. 15 I understand that access to information designated as “CONFIDENTIAL” is 16 provided to me under the terms and restrictions of a Protective Order. I have received a 17 copy of the Protective Order, have read it, and agree to be bound by its terms. I will not 18 mention, disclose, or use information designated as “Confidential” that is provided to me 19 in connection with this action except as permitted by the Protective Order. 20 Dated: ________________________________, 2021 21 22 23 Signature: _____________________________ Print Name: ____________________________ 24 Title: _________________________________ 25 Company: _____________________________ 26 27 28 ___________________________________________________________________________________ STIPULATED PROTECTIVE ORDER 16

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