Mathein v. Pier 1 Imports, Inc. et al
Filing
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STIPULATED PROTECTIVE ORDER. Signed by Magistrate Judge Stanley A. Boone on 9/2/2016. (Hernandez, M)
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AKIN GUMP STRAUSS HAUER & FELD LLP
GREGORY W. KNOPP (SBN 237615)
GALIT A. KNOTZ (SBN 252962)
gknopp@akingump.com
gknotz@akingump.com
1999 Avenue of the Stars, Suite 600
Los Angeles, CA 90067
Telephone: 310.229.1000
Facsimile: 310.229.1001
Attorneys for Defendants,
PIER 1 IMPORTS (U.S.), INC.
PIER 1 IMPORTS, INC.
MARLIN & SALTZMAN, LLP
STANLEY D. SALTZMAN (SBN 090058)
DAVID LEIMBACH (SBN 265409)
ssaltzman@marlinsaltzman.com
dleimbach@marlinsaltzman.com
29229 Canwood Street, Suite 208
Agoura Hills, California 91301
Telephone: (818) 991-8080
Facsimile: (818) 991-8081
Attorneys for Plaintiff,
LAUREN MATHEIN
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA - FRESNO DIVISION
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LAUREN MATHEIN, individually
and on behalf of all others similarly
situated,
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Plaintiffs,
v.
PIER 1 IMPORTS, INC.; PIER 1
IMPORTS (U.S.), INC.; and DOES 1
to 100, inclusive,
Defendants.
Case No. 1:16-cv-00087- DAD-SAB
STIPULATED PROTECTIVE
ORDER
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1.
PURPOSES AND LIMITATIONS
Disclosure and discovery activity in this action are likely to involve production of
confidential, proprietary, or private information for which special protection from public
disclosure and from use for any purpose other than prosecuting 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. 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; Civil Local Rule 141 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.
2.
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 how
it is generated, stored or maintained) or tangible things that qualify for protection under
Federal Rule of Civil Procedure 26(c).
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
items that it produces in disclosures or in responses to discovery as
―CONFIDENTIAL.‖
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, among
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other things, testimony, transcripts, and tangible things), that are produced or generated
in disclosures or responses to discovery in this matter.
2.6
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.
2.7
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.
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 to
this action but are retained to represent or advise a party to this action and have
appeared in this action on behalf of that party or are affiliated with a law firm which has
appeared on behalf of that party.
2.10 Party: any party to this action, including all of its officers, directors,
employees, consultants, retained experts, and Outside Counsel of Record (and their
support staffs).
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
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.
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.
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3.
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. However, the protections conferred by
this Stipulation and Order do not cover the following information: (a) any information
that is in the public domain at the time of disclosure to a Receiving Party or becomes
part of the public domain after its disclosure to a Receiving Party as a result of
publication not involving a violation of this Order, including becoming part of the
public record through trial or otherwise; and (b) any information known to the
Receiving Party prior to the disclosure or obtained by the Receiving Party after the
disclosure from a source who obtained the information lawfully and under no obligation
of confidentiality to the Designating Party. Any use of Protected Material at trial shall
be governed by a separate agreement or order.
4.
DURATION
Even after final disposition of this litigation, the confidentiality obligations
imposed by this Order shall remain in effect until a Designating Party agrees otherwise
in writing or a court order otherwise directs. Final disposition shall be deemed to be the
later of (1) dismissal of all claims and defenses in this action, with or without prejudice;
and (2) final judgment herein after the completion and exhaustion of all appeals,
rehearings, remands, trials, or reviews of this action, including the time limits for filing
any motions or applications for extension of time pursuant to applicable law.
5.
DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection.
Each Party or Non-Party that designates information or items for protection under this
Order must take care to limit any such designation to specific material that qualifies
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under the appropriate standards. The Designating Party must designate for protection
only those 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 or retard the case development process or to impose
unnecessary expenses and burdens on other parties) expose the Designating Party to
sanctions.
If it comes to a Designating Party’s attention that information or items that it
designated for protection do not qualify for protection, that Designating Party must
promptly notify all other Parties that it is withdrawing the mistaken designation.
While the parties must exercise restraint, a Designating Party has the right to
designate as ―Confidential‖ any material that the Designating Party in good faith
believes to contain non-public information that is entitled to confidential treatment
under applicable law, specifically including, but not limited to, any employee payroll
data, employee personnel data and/or contact information, or Pier 1 Imports (U.S.), Inc.
or Pier 1 Imports, Inc.’s (collectively, ―Pier 1‖) internal policies, practices or strategies.
5.2
Manner and Timing of Designations. Except as otherwise provided in this
Order (see, e.g., section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
or Discovery Material that qualifies for protection under this Order must be clearly so
designated before the material is disclosed or produced.
Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic documents, but
excluding transcripts of depositions or other pretrial or trial proceedings), that the
Producing Party affix the legend ―CONFIDENTIAL‖ to each page that contains
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protected material. If only a portion or portions 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). A Party or Non-Party that makes
original documents or materials available for inspection need not designate them for
protection until after the inspecting Party has indicated which material it would like
copied and produced. 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 or portions 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 deposition or in other pretrial or trial proceedings, that
the Designating Party identify within thirty days of the close of the deposition, hearing,
or other proceeding, all protected testimony.
(c) for information produced in some form other than documentary and for any
other tangible items, that the Producing Party affix in a prominent place on the exterior
of the container or containers in which the information or item is stored the legend
―CONFIDENTIAL.‖ If only a portion or portions of the information or item warrant
protection, the Producing Party, to the extent practicable, shall identify the protected
portion(s).
5.3
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
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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.
6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
Timing of Challenges. Any Party or Non-Party may challenge a
designation of confidentiality at any time, with the exception of Personal Contact
Information, as explained below. Unless a prompt challenge to a Designating Party’s
confidentiality designation is necessary to avoid foreseeable, substantial unfairness,
unnecessary economic burdens, or a significant disruption or delay of the litigation, a
Party does not waive its right to challenge a confidentiality designation by electing not
to mount a challenge promptly after the original designation is disclosed.
Any contact information of Pier 1’s current or former employees that Pier 1
produces at any time during the course of, or in connection with this litigation
(―Personal Contact Information‖), shall be deemed Confidential, whether or not
stamped or marked as confidential. The designation of Personal Contact Information as
confidential shall not be subject to objections pursuant to Paragraph 6 (or its subparts)
of this Order. Any Personal Contact Information shall be used by Lauren Mathein and
her counsel solely for the purpose of investigating, prosecuting, and/or settlement of this
litigation.
6.2
Meet and Confer. The Challenging Party shall initiate the dispute
resolution process by providing written notice of each designation it is challenging and
describing the basis for each challenge. To avoid ambiguity as to whether a challenge
has been made, the written notice must recite that the challenge to confidentiality is
being made in accordance with this specific paragraph of the Protective Order. The
parties shall attempt to resolve each challenge in good faith and must begin the process
by conferring directly (in voice to voice dialogue; other forms of communication are not
sufficient) within 14 days of the date of service of notice. In conferring, the
Challenging Party must explain the basis for its belief that the confidentiality
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designation was not proper and must give the Designating Party an opportunity to
review the designated material, to reconsider the circumstances, and, if no change in
designation is offered, to explain the basis for the chosen designation. A Challenging
Party may proceed to the next stage of the challenge process only if it has engaged in
this meet and confer process first or establishes that the Designating Party is unwilling
to participate in the meet and confer process in a timely manner.
6.3
Judicial Intervention. If the Parties cannot resolve a challenge without
court intervention, any party may file and serve a that identifies the challenged material
and sets forth in detail the basis for the challenge within 21 days of the parties agreeing
that the meet and confer process will not resolve their dispute. Any motion brought
pursuant to this provision must be accompanied by a competent declaration affirming
that the movant has complied with the meet and confer requirements imposed by the
preceding paragraph.
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. All parties shall continue to afford the material in
question the level of protection to which it is entitled under the Producing Party’s
designation until the court rules on the challenge.
7.
ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
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 case
only for prosecuting, defending, or attempting to settle this litigation. Such Protected
Material may be disclosed only to the categories of persons and under the conditions
described in this Order. When the litigation has been terminated, a Receiving Party
must comply with the provisions of section 13 below (FINAL DISPOSITION).
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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.
7.2
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 litigation and who have signed the ―Acknowledgment
and Agreement to Be Bound‖ that is attached hereto as Exhibit A;
(b) the officers, directors, and employees (including House Counsel) of the
Receiving Party to whom disclosure is reasonably necessary for this litigation and who
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
is reasonably necessary for this litigation and who have signed the ―Acknowledgment
and Agreement to Be Bound‖ (Exhibit A);
(d) the court and its personnel;
(e) court reporters and their staff, professional jury or trial consultants, mock
jurors, and Professional Vendors to whom disclosure is reasonably necessary for this
litigation and who have signed the ―Acknowledgment and Agreement to Be Bound‖
(Exhibit A);
(f) during their depositions, witnesses in the action to whom disclosure is
reasonably necessary and who have signed the ―Acknowledgment and Agreement to Be
Bound‖ (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the
court. Pages of transcribed deposition testimony or exhibits to depositions that reveal
Protected Material must be separately bound by the court reporter and may not be
disclosed to anyone except as permitted under this Stipulated Protective Order.
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(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information.
8.
OTHER LITIGATION
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PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
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
issue in the other litigation that some or all of the material covered by the subpoena or
order is subject to this Protective Order. Such notification shall include a copy of this
Stipulated Protective Order; and
(c) Cooperate with respect to all reasonable procedures sought to be pursued by
the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with the
subpoena or court order shall not produce any information designated in this action as
―CONFIDENTIAL‖ before a determination by the court from which the subpoena or
order issued, unless the Party has obtained the Designating Party’s permission. The
Designating Party shall bear the 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.
9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
IN THIS LITIGATION
(a) The terms of this Order are applicable to information produced by a Non-
Party in this action and designated as ―CONFIDENTIAL.‖ Such information produced
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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.
(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
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 litigation, 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 NonParty.
(c) If the Non-Party fails to object or seek a protective order from this court
within 14 days of receiving the notice and accompanying information, the Receiving
Party may produce the Non-Party’s confidential information responsive to the discovery
request. If the Non-Party timely seeks a protective order, the Receiving Party shall not
produce any 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 contrary, the Non-Party shall bear the burden and expense of seeking protection in
this court of its Protected Material.
10.
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
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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 and Agreement to Be Bound‖
that is attached hereto as Exhibit A.
11.
PROTECTED MATERIAL
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INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
When a Producing Party gives notice to Receiving Parties that certain
inadvertently produced material is subject to a claim of privilege or other protection, the
obligations of the Receiving Parties are those set forth in Federal Rule of Civil
Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
may be established in an e-discovery order that provides for production without prior
privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
parties reach an agreement on the effect of disclosure of a communication or
information covered by the attorney-client privilege or work product protection, the
parties may incorporate their agreement in the stipulated protective order submitted to
the court.
12.
MISCELLANEOUS
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
person to seek its modification by the court in the future.
12.2 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 to disclosing
or producing any information or item on any ground not addressed in this Stipulated
Protective Order. Similarly, no Party waives any right to object on any ground to use in
evidence of any of the material covered by this Protective Order.
12.3 Filing Protected Material. Without written permission from the
Designating Party or a court order secured after appropriate notice to all interested
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persons, a Party may not file in the public record in this action any Protected Material.
A Party that seeks to file under seal any Protected Material must comply with Civil
Local Rule 141. Protected Material may only be filed under seal pursuant to a court
order authorizing the sealing of the specific Protected Material at issue. If a Receiving
Party's request to file Protected Material under seal pursuant to Civil Local Rule 141 is
denied by the court, then the Receiving Party may file the information in the public
record pursuant to Civil Local Rule 141 unless otherwise instructed by the court.
13.
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
destroy such material. As used in this subdivision, ―all Protected Material‖ includes all
copies, abstracts, compilations, summaries, and any other format reproducing or
capturing any of the Protected Material. Whether the Protected Material is returned or
destroyed, the Receiving Party must submit a written certification 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 work product, even if
such materials contain Protected Material. Any such archival copies that contain or
constitute Protected Material remain subject to this Protective Order as set forth in
Section 4 (DURATION).
///
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated: September 2, 2016
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By
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AKIN GUMP STRAUSS HAUER & FELD LLP
GREGORY W. KNOPP
GALIT A. KNOTZ
Dated: September 2, 2016
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/s/ Gregory W. Knopp**
Gregory W. Knopp
Attorneys for Defendants
PIER 1 IMPORTS, INC. &
PIER 1 IMPORTS (U.S.), INC.
MARLIN & SALTZMAN, LLP
By/s/ David Leimbach (as authorized on 8/26/16)
David Leimbach
Attorneys for Plaintiff
LAUREN MATHEIN
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**Pursuant to L.R. 131(e), I attest that concurrence in the filing of this document has
been obtained from each of the above other signatories.
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ORDER
Pursuant to the stipulation of the parties, IT IS HEREBY ORDERED that:
1.
The protective order is entered in this action;
2.
The parties are advised that pursuant to the Local Rules of the United
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States District Court, Eastern District of California, any documents which
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are to be filed under seal will require a written request which complies with
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Local Rule 141; and
3.
The party making a request to file documents under seal shall be required
to show good cause for documents attached to a nondispositive motion or
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compelling reasons for documents attached to a dispositive motion. Pintos
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v. Pacific Creditors Ass’n, 605 F.3d 665, 677-78 (9th Cir. 2009).
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IT IS SO ORDERED.
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Dated:
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September 2, 2016
UNITED STATES MAGISTRATE JUDGE
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
I, _____________________________ [print or type full name], of _________________
[print or type full address], declare under penalty of perjury that I have read in its entirety
and understand the Stipulated Protective Order that was issued by the United States
District Court for the Eastern District of California on [date] in the case of Lauren
Mathein v. Pier 1 Imports, Inc., Case No. 1:16-cv-0087-DAD-SAB, currently pending in
the Eastern District of California. I agree to comply with and to be bound by all the terms
of this Stipulated Protective Order and I understand and acknowledge that failure to so
comply could expose me to sanctions and punishment in the nature of contempt. I
solemnly promise that I will not disclose in any manner any information or item that is
subject to this Stipulated Protective Order to any person or entity except in strict
compliance with the provisions of this Order.
I further agree to submit to the jurisdiction of the United States District Court for
the Eastern District of California for the purpose of enforcing the terms of this Stipulated
Protective Order, even if such enforcement proceedings occur after termination of this
action.
I hereby appoint __________________________ [print or type full name] of
_______________________________________ [print or type full address and telephone
number] as my California agent for service of process in connection with this action or
any proceedings related to enforcement of this Stipulated Protective Order.
Date: ______________________________________
City and State where sworn and signed: _________________________________
Printed name: _______________________________
Signature: __________________________________
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