Interval Equipment Solutions, Inc. v. Sandvik Mining and Construction USA, LLC

Filing 16

STIPULATED PROTECTIVE ORDER, signed by Magistrate Judge Sheila K. Oberto on 7/19/2016. (Kusamura, W)

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MORGAN, LEWIS & BOCKIUS LLP
BRENDAN E. RADKE, Cal. Bar No. 275284
[e-mail]
KEVIN M. BENEDICTO, Cal. Bar No. 305802
[e-mail]
One Market Street, Spear Street Tower
San Francisco, CA 94105-1596
Tel: [phone]

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MORGAN, LEWIS & BOCKIUS LLP
R. BRENDAN FEE, pro hac vice
[e-mail]
1701 Market Street
Philadelphia, PA 19103-2921
Tel: [phone]

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Attorneys for Defendant/Counterclaim Plaintiffs

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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Case No.1:16-cv-00512-LJO-SKO

INTERVAL EQUIPMENT SOLUTIONS,
INC.,

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STIPULATED PROTECTIVE ORDER
Plaintiff,

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vs.
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SANDVIK MINING AND CONSTRUCTION
USA, LLC and DOES 1-10,

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Defendants.

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SANDVIK MINING AND CONSTRUCTION
USA, LLC and SANDVIK INTELLECTUAL
PROPERTY AB

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Counterclaim Plaintiffs,

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vs.
INTERVAL EQUIPMENT SOLUTIONS,
INC.
Counterclaim Defendant.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATED PROTECTIVE ORDER

Case No. 1:16-cv-00512-LJO-SKO

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1.

PURPOSES AND LIMITATIONS
Disclosure and discovery in this action are likely to involve production of confidential,

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proprietary, or private information. Special protection from public disclosure and use for any

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purpose other than prosecuting this litigation may be warranted. Plaintiff/Counterclaim

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Defendant Interval Equipment Solutions Inc. (“Interval”), Defendant/Counterclaim Plaintiff

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Sandvik Mining and Construction USA LLC, and Counterclaim Plaintiff Sandvik Intellectual

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Property AB (collectively, “Sandvik”) have therefore agreed to the terms of the Stipulated

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Protective Order (“Order”) as set forth below. Interval and Sandvik (collectively, the “Parties”)

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enter into this agreement to protect the confidentiality of materials containing trade secrets and

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technical, cost, price, sales, marketing or other commercial information, as contemplated by

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Federal Rule of Civil Procedure 26(c). Accordingly, the Parties hereby stipulate to and petition

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the Court to enter the following Order. The Parties acknowledge that the Order does not confer

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blanket protections on all disclosures or responses to discovery and that the protection it affords

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from public disclosure and use extends only to the limited information or items entitled to

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confidential treatment under applicable legal principles.

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As required by Civil Local Rule 141.1(c)(3), the Parties submit that protection should be

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addressed by a Court Order, as opposed to a private agreement between or among the Parties.

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The nature of the claims involved in this action may require discovery into competitively

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sensitive information, including potentially from third parties. A private agreement between the

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Parties would be insufficient to alleviate the Parties’ concerns that such information remain

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confidential. Good cause exists for entry of a protective order to prevent unauthorized disclosure

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and use of trade secrets and confidential commercial information of Parties and Non-Parties

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during the litigation and after it has been concluded. A protective order will also facilitate timely

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production of material from both Parties and Non-Parties. Given these concerns, the Parties

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respectfully request the entry of this Order by the Court.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATED PROTECTIVE ORDER

Case No. 1:16-cv-00512-LJO-SKO

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2.

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DEFINITIONS
2.1.

“CONFIDENTIAL” Information or Items: Information (regardless of how

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generated, stored, or maintained) or tangible things that are treated confidentially by a Party or

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Non-Party.

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2.2.

Designating Party: A Party or Non-Party that designates information or items

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that it produces in disclosures or in responses to discovery as “CONFIDENTIAL” or “HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”

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2.3.

Disclosure or Discovery Material: All items or information, regardless of the

medium or manner generated, stored, or maintained (including, among other things, testimony,

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transcripts, or tangible things) that are produced or generated in disclosures or responses to

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discovery in this matter.

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2.4.

Expert: A person with specialized knowledge or experience in a matter pertinent

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to the litigation who has been retained by a Party or its counsel to serve as an expert witness or

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consultant in this action and who is not a current employee of a Party or of a competitor of a

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Party.

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2.5.

“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Information

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and Items: Extremely sensitive “CONFIDENTIAL Information or Items,” the disclosure of

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which would result in the disclosure of information only known on a “need-to-know basis” and

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generally not known by individuals not affiliated with a Party, including sensitive information in

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the categories of (1) trade secrets, (2) other competitively sensitive research, (3) development, (4)

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production, (5) personnel, (6) commercial, (7) technical, (8) financial, or (9) business information

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(with information in these categories including but not limited to proprietary information,

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contracts, bids, corporate planning documents, strategic planning documents, documents that

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reveal market or customer analyses, competitive strategy, research and development documents,

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financial statements, and other financial or budgetary documents). There is a particularized need

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for information in each of these categories to be covered by the Order to protect its highly

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sensitive and confidential nature, as disclosure could create a substantial risk of harm to the

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Designating Party that could not be avoided by less restrictive means.
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Case No. 1:16-cv-00512-LJO-SKO

MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

STIPULATED PROTECTIVE ORDER

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2.6.

Discovery Material in this action.

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2.7.

2.8.

Party: Any Party to this action, including all of its officers, directors, employees,

consultants, retained experts, general counsel, outside counsel and their support staff.

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Outside Counsel: Attorneys who are not employees of a Party but who are

retained to represent or advise a Party in this action, including their support staff.

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Non-Party: Any person or entity that is not a Party that produces Disclosure or

2.9.

Producing Party: A Party or Non-party that produces Disclosure or Discovery

Material in this action.

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2.10.

Professional Vendors: Persons or entities that provide litigation support services

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(including but not limited to photocopying, videotaping, translating, preparing exhibits or

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demonstrations, organizing, storing, and retrieving data in any form or medium), as well as their

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employees and subcontractors.

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2.11.

Protected Material: Any Disclosure or Discovery Material that is designated as

“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”

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2.12.

Receiving Party: A Party that receives Disclosure or Discovery Material from a

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Producing Party.

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3.

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SCOPE
The protections conferred by this Order cover not only Protected Material (as defined

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above), but also any information copied or extracted therefrom, as well as all copies, excerpts,

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summaries, or compilations thereof, plus testimony, conversations, or presentations by Parties or

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Outside Counsel to or in Court proceedings or in other settings that might reveal Protected

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Material.

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4.

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DURATION
Even after the termination of this litigation, the confidentiality obligations imposed by this

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Order shall remain in effect until a Designating Party agrees otherwise in writing or the Court’s

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order otherwise directs.

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5.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

DESIGNATING PROTECTED MATERIAL
5.1.

Exercise of Restraint and Care in Designating Material for Protection.
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Case No. 1:16-cv-00512-LJO-SKO
STIPULATED PROTECTIVE ORDER

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Each Producing Party that designates information or items for protection under this Order

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must take care to limit any such designation to specific material that qualifies under the

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appropriate standards. A Designating Party must take care to designate for protection only those

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parts of the material, documents, items, or oral or written communication that qualify so that

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other portions of the material, documents, items, or communications for which protection is not

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warranted are not swept unjustifiability within the ambit of this Order.

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If it comes to a Designating Party’s attention that information or items that it designated

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for protection do not qualify for protection, the Designating Party must promptly notify all other

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Parties that it is withdrawing the mistaken designation.

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5.2.

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Except as otherwise provided in this Order, or as otherwise stipulated or ordered,

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Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so

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designated before the material is disclosed or produced.

Manner and Timing of Designations.

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Designation in conformity with this Order requires:

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Information in documentary form (e.g., paper or electronic documents, excluding

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transcripts of depositions or other pretrial or trial proceedings): The Producing Party shall affix

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the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”

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at the top or bottom of each page that contains protected material, in such a manner that will not

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interfere with the legibility of the document.

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Testimony given in deposition or in other pretrial or trial proceedings: The Producing

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Party offering or sponsoring the testimony shall identify on the record, before the close of the

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deposition, hearing, or other proceeding, all protected testimony. When it is impractical to

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identify separately each portion of testimony that is entitled to protection, and when it appears

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that substantial portions of the testimony may qualify for protection, the Party or Non-Party that

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sponsors, offers, or gives the testimony may invoke on the record (before the deposition or

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proceeding is concluded) a right to have up to fourteen (14) days following mailing of the

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transcript by the court reporter to identify the specific portions of the testimony as to which

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protection is sought. Counsel attending a deposition who inadvertently fail to designate any
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Case No. 1:16-cv-00512-LJO-SKO

MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

STIPULATED PROTECTIVE ORDER

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portion of the transcript as confidential on the record at the deposition shall have fourteen (14)

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days following mailing of the transcript by the court reporter to do so. Only those portions of the

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testimony that are appropriately designated for protection within the fourteen (14) days following

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mailing of the transcript by the court reporter shall be covered by the provisions of this Order.

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Until expiration of the aforesaid fourteen (14) day period, all deposition transcripts shall be

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considered and treated as confidential material, unless otherwise agreed on the record at the

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deposition.

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Transcript pages containing Protected Material must be separately identified by the court
reporter, who must affix to the top of each such page the legend “CONFIDENTIAL” or

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“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” as instructed by the party or non-

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party offering or sponsoring the witness or presenting the testimony.

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Information produced in some form other than documentary and for any other tangible

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items: The Producing Party shall affix, in a prominent place on the exterior of the container or

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containers in which the information or item is stored, the legend “CONFIDENTIAL” or

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“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” If only portions of the

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information or item warrant protection, the Producing Party, to the extent practicable, shall

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identify the protected portions, specifying whether they qualify as “CONFIDENTIAL” or

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“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”

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6.

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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1.

Timing of Challenges: Unless a prompt challenge to Designating Party’s

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confidentiality designation is necessary to avoid foreseeable substantial unfairness, unnecessary

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economic burdens, or a later significant disruption or delay of the litigation, a Party does not

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waive its right to challenge a confidentiality designation by electing not to mount a challenge

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promptly after the original designation is disclosed.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATED PROTECTIVE ORDER

Case No. 1:16-cv-00512-LJO-SKO

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6.2.

Meet and Confer: A Party that objects to a Designating Party’s confidentiality

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designation must do so in good faith and must begin the process of conferring directly (in

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voice to voice dialogue or by written communication) with counsel for the Designating Party. In

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conferring, the challenging Party must explain the basis for its belief that the confidentiality

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designation was improper and must give the Designating Party an opportunity to review the

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designated material, to reconsider the circumstances, and, if no change in designation is offered,

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to explain the basis for the chosen designation. A challenging Party may proceed to the next

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stage of the challenge process only if it has engaged in this meet and confer process first or

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establishes that the Designating Party is unwilling to participate in the meet and confer process in

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a timely manner.

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6.3.

Judicial Intervention: If the Parties cannot reach an agreement regarding the

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propriety of a challenged confidentiality designation, the challenging Party shall file and serve a

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motion challenging the designation under Civil Local Rule 251 within twenty-one (21) days of

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the initial notice of challenge or within fourteen (14) days of the parties agreeing that the meet

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and confer process will not resolve their dispute, whichever is earlier.

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The burden of persuasion in any such challenge proceeding shall be on the Designating

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Party. Frivolous challenges and those made for an improper purpose (e.g., to harass or impose

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unnecessary expenses and burdens on other parties) may expose the challenging Party to

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sanctions. All parties shall continue to afford the material in question the level of protection to

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which it is entitled under the Producing Party’s designation until the Court rules on the challenge.

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7.

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ACCESS TO AND USE OF PROTECTED MATERIAL
7.1.

Basic Principles: A Receiving Party may use Protected Material disclosed or

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produced by another Party or Non-Party in connection with this case only for prosecuting,

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defending, or attempting to settle this litigation. Such Protected Material may be disclosed only

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to the categories of persons and under the conditions described in this Order. When the litigation

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has been terminated, a Receiving Party must comply with the provisions of Section 13 below.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

Protected Material must be stored and maintained by a Receiving Party at a location and
in a secure manner that is consistent with the firm’s storage of client files.
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Case No. 1:16-cv-00512-LJO-SKO
STIPULATED PROTECTIVE ORDER

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7.2.

Disclosure of “CONFIDENTIAL” Information or Items: Unless otherwise

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ordered by the Court or permitted in writing by the Designating Party, a Receiving Party may

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disclose any information or item designated “CONFIDENTIAL” only to:

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(a)

the Receiving Party’s Outside Counsel, as defined in Section 2.6 of this

(b)

the General Counsel, officers, directors, and employees of the Receiving

Order;

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Party to whom disclosure is reasonably necessary for this litigation and who have signed the

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“Acknowledgment and Agreement to be Bound” attached hereto as Exhibit A;

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(c)

Experts (as defined in this Order) of the Receiving Party to whom

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disclosure is reasonably necessary and who have signed the “Acknowledgement and Agreement

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to be Bound” attached hereto as Exhibit A;

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(d)

the Court and its personnel;

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(e)

court reporters, their staffs, and Professional Vendors (as defined in this

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Order) to whom disclosure is reasonably necessary;

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(f)

professional jury or trial consultants, and to whom disclosure is reasonably

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necessary for this litigation and who have signed the “Acknowledgment and Agreement to be

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Bound” attached hereto as Exhibit A;

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(g)

witnesses in the action to whom disclosure is reasonably necessary and

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who have signed the “Acknowledgment and Agreement to Be Bound” attached hereto as

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Exhibit A;

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(h)

the author of the document or the original source of the information; and

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(i)

mediators or other ADR professionals retained by the Parties.

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7.3.

Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY”

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Information or Items: Unless otherwise ordered by the Court or permitted in writing by the

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Designating Party, a Receiving Party may disclose any information or item designated “HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only to:

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

(a)

the Receiving Party’s Outside Counsel, as defined in Section 2.6 of this

Order;
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STIPULATED PROTECTIVE ORDER

Case No. 1:16-cv-00512-LJO-SKO

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(b)

Experts (as defined in this Order) of the Receiving Party to whom

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disclosure is reasonably necessary and who have signed the “Acknowledgment and Agreement to

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be Bound” attached hereto as Exhibit A;

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(c)

the Court and its personnel;

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(d)

Court reporters and their staff, Professional Venders to whom disclosure is

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reasonably necessary;

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(e)

professional jury or trial consultants, and to whom disclosure is reasonably

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necessary for this litigation and who have signed the “Acknowledgment and Agreement to be

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Bound” attached hereto as Exhibit A;

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(f)

the author or recipient of a document containing the information or a

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custodian or other person who otherwise possessed or knew the information as confirmed by

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written records; and

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(g)
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mediators or other ADR professionals retained by the Parties.

PROTECTED MATERIAL SOUGHT IN OTHER LITIGATION

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If a Receiving Party is served with a subpoena or an order issued in another litigation that
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would compel disclosure of any information or items designated in this action as
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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY,” the
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Receiving Party must promptly notify the Designating Party, in writing, within sufficient time to
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allow the Designating Party to seek relief to stop the production of such Protected Material. Such
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notification must include a copy of the subpoena or court order.
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The purpose of imposing this duty is to afford the Designating Party in this case an
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opportunity to try to protect its confidentiality interests in the court from which the subpoena or
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order is issued. The Designating Party shall bear the burdens and the expenses of seeking
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protection in that court of its confidential material and nothing in these provisions should be
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construed as authorizing or encouraging a Receiving Party in this action to disobey a lawful
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directive from another court.
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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATED PROTECTIVE ORDER

Case No. 1:16-cv-00512-LJO-SKO

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9.

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UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected

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Material to any person or in any circumstance not authorized under this Order, the Receiving

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Party must immediately (a) notify in writing the Designating Party of the unauthorized

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disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material,

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(c) inform the person(s) to whom unauthorized disclosures were made of all the terms of this

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Order, and (d) request such person(s) execute the “Acknowledgment and Agreement to be

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Bound” attached hereto as Exhibit A.

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10.

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FILING PROTECTED MATERIAL
Without written permission from the Designating Party or a court order secured after

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appropriate notice to all interested persons, a Party may not file in the public record in this action

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any Protected Material. Whenever any writing, testimony, information, or material designated as

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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” is to be

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filed with the Court, the Parties shall follow the procedures for filing records under seal set forth

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in Civil Local Rule 141. Protected Material may only be filed under seal pursuant to a court order

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authorizing the sealing of the specific Protected Material at issue. Pursuant to Civil Local Rule

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140, where possible, a Party must also seek to publicly file material with the Protected Material

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redacted, provided that the Court has also granted the filing of an unredacted copy of the material

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under seal.

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INADVERTENT PRODUCTION OF PROTECTED MATERIAL

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Notwithstanding anything contrary herein, if a Party or Non-Party through inadvertence or
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mistake produces any Protected Material without designating it with the legend
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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY,” the
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Producing Party may give written notice to the Receiving Party that the Disclosure or Discovery
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Material contains Protected Material and should be treated as such in accordance with the
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provisions of this Order. Upon receipt of such notice, the Receiving Party must treat such
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Disclosure or Discovery Material as Protected Material. Outside Counsel for the Parties will
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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATED PROTECTIVE ORDER

Case No. 1:16-cv-00512-LJO-SKO

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agree on a mutually acceptable manner of labeling or marking the inadvertently produced

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materials as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

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ONLY.” The inadvertent or unintentional disclosure by the Producing Party of Protected

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Material, regardless of whether the information was so designated at the time of disclosure, shall

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not be deemed a waiver in whole or in party of the Producing Party’s claim of confidentiality

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either as to the specific information disclosed, or as to any other information relating thereto or on

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the same or related subject matter. The Receiving Party shall not be responsible for the disclosure

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or other distribution of belatedly designated Protected Material as to such disclosure or

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distribution that may occur before the receipt of such notification of a claim of confidentiality and

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such disclosure or distribution shall not be deemed to be a violation of this Order.

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12.

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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.

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12.2.

Right to Assert Other Objections: By stipulating to the entry of this Order, no

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Party waives any right it otherwise would have to object to disclosing or producing any

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information or item on any ground not addressed in this Order. Similarly, no Party waives any

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right to object on any ground to use in evidence any of the material covered by this Order.

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13.

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FINAL DISPOSITION
Within sixty (60) days after the final termination of this action, a Receiving Party shall,

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upon written notice from the Designating Party, either return or certify in writing to the Producing

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Party that all “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

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ONLY” information has been destroyed. The written certification shall state that the Receiving

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Party has not retained copies of the “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –

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ATTORNEYS’ EYES ONLY” information, except that Outside Counsel are entitled to retain an

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archival copy of all pleadings, motions, papers, transcripts, legal memoranda, correspondence, or

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attorney work product that may contain such “CONFIDENTIAL” or “HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information. Archival copies shall, however,

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remain subject to this Order, as set forth in Section 4 above.
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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

STIPULATED PROTECTIVE ORDER

Case No. 1:16-cv-00512-LJO-SKO

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IT IS SO STIPULATED.

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Dated: July 19, 2016

Respectfully submitted,
MORGAN, LEWIS & BOCKIUS LLP

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By /s/ R. Brendan Fee
R. Brendan Fee
Brendan E. Radke
Kevin M. Benedicto

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Attorneys for Defendant and CounterComplainants

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LAW OFFICES OF MICHAEL R.
BARRETTE

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Dated: July 19, 2016

By /s/ Michael R. Barrette
Michael R. Barrette

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Attorney for Plaintiff and Counter
Defendant

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IT IS SO ORDERED.

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Dated: July

20, 2016

/s/

Sheila K. Oberto .

UNITED STATES MAGISTRATE JUDGE

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATED PROTECTIVE ORDER

Case No. 1:16-cv-00512-LJO-SKO

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I,

, declare and say that:

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1.

I am employed as

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2.

I have read in its entirety and understand the Stipulated Protective Order that was

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by

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issued by the United States District Court for the Eastern District of California on

in the

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case of Interval Equipment Solutions Inc. v. Sandvik Mining and Construction USA LLC, Case
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No. 1:16-cv-00512-LJO-SKO (“Protective Order”). I hereby agree to comply with and be bound
by all of the terms and conditions of this Protective Order.
3.

I promise that I will use any and all “CONFIDENTIAL” or “HIGHLY

CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information, as defined in the Protective
Order, given to me only in a manner authorized by the Protective Order, and only to assist
counsel in the litigation of this matter.

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4.

I promise that I will not disclose or discuss such “CONFIDENTIAL” or

“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information with anyone other
than the persons authorized in accordance with Section 7.2 and 7.3 of the Protective Order.
5.

When I have completed by assigned or legal duties relating to this litigation, I will

promptly return or destroy all Protected Material in my possession, or that I have prepared
relating to such Protected Material, to counsel for the Party by whom I am employed or retained.

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I acknowledge that such return or the subsequent destruction of such materials shall not relieve
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me from any of the continuing obligations imposed on me by the Protective Order.
6.

I acknowledge that, by signing this agreement, I am subjecting myself to the

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jurisdiction of the United States District Court for the Eastern District of California with respect

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to enforcement of the Protective Order.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATED PROTECTIVE ORDER

Case No. 1:16-cv-00512-LJO-SKO

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7.

I understand that any disclosure or use of “CONFIDENTIAL” or “HIGHLY

CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information in any manner contrary to the
provisions of the Protective Order may subject me to sanctions for contempt of court.

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I declare under penalty of perjury that the foregoing is true and correct.

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Executed this

day of

, 2016 at

.

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____________________________________

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

14
STIPULATED PROTECTIVE ORDER

Case No. 1:16-cv-00512-LJO-SKO