U.S. Equal Employment Opportunity Commission v. Prestige Care, Inc. et al

Filing 67

STIPULATED PROTECTIVE ORDER for Settlement Disclosures, signed by Magistrate Judge Barbara A. McAuliffe on 12/27/2018. Following review, the Court HEREBY ADOPTS the Stipulated Protective Order for Settlement Disclosures submitted by the parties. (Valdez, E)

1
2
3
4
5
6
7
8
9
10
11

Anna Y. Park, SBN 164242
Sue J. Noh, SBN 192134
Rumduol Vuong, SBN 264392
Nakkisa Akhavan, SBN 286260
Jennifer L. Boulton, SBN 259076
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
255 East Temple Street, Fourth Floor
Los Angeles, CA 90012
Telephone: [phone]
Facsimile: [phone]
E Mail: [e-mail]
Attorneys for Plaintiff
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
(Additional counsel listed on p.3)

12
13

UNITED STATES DISTRICT COURT

14

EASTERN DISTRICT OF CALIFORNIA

15
16

U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION,

17

Plaintiff,

18
vs.
19
20
21
22
23
24
25
26
27
28

PRESTIGE CARE, INC., PRESTIGE
SENIOR LIVING, LLC, CYPRESS POINT
VENTURES, LLC, PRESTIGE SENIOR
MANAGEMENT, LLC, CARE CENTER
(ANCHORAGE), INC., GREEN VALLEY
VENTURES, LLC, LAKE HAVASU TOO,
LLC, SIERRA VISTA VENTURES, LLC,
CHICO VENTURES, LLC, MANTECA
VENTURES, LLC, MARYSVILLE
VENTURES, LLC, OROVILLE ASSISTED
LIVING, LLC, VISALIA VENTURES, LLC,
CARE CENTER (LEWISTON), INC.,
CALDWELL VENTURES, LLC,
PARKWOOD MEADOWS, LLC,
KALISPELL VENTURES, LLC,

)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)

Case No.: 1:17-cv-01299-AWI-SAB
STIPULATED PROTECTIVE ORDER
FOR SETTLEMENT DISCLOSURES;
ORDER

-1STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

HENDERSON VENTURES II, LLC, CARE
CENTER (GLISAN), INC., CARE CENTER
(HOOD RIVER), INC., CARE CENTER
(LANECO), INC., CARE CENTER (LINDA
VISTA), INC., CARE CENTER (MENLO
PARK), INC., CARE CENTER
(PORTHAVEN), INC., CARE CENTER
(WILLOWBROOK), INC., PCI CARE
VENTURE I, INC., SUMMERPLACE
ASSISTED LIVING, LLC, CARE CENTER
(CAMAS), INC., CARE CENTER
(CENTRALIA), INC., CARE CENTER
(COLVILLE), INC., CARE CENTER
(EDMONDS), INC., CARE CENTER
(HAZEL DELL), INC., CARE CENTER
(SULLIVAN PARK), INC., CARE CENTER
(SUNNYSIDE), INC., CARE CENTER
(TOPPENISH), INC., GIG HARBOR
VENTURES, LLC, LIVING COURT
VENTURES, LLC, ENUMCLAW
VENTURES II, LLC, AND DOES 1-100,
INCLUSIVE,
Defendants.

)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)

16
17
18
19
20
21
22
23
24
25
26
27
28

-2STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1
2
3
4
5
6
7
8
9
10
11

Additional Counsel for the EEOC:
Nechole M. Garcia, NV SBN 12746
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
333 Las Vegas Boulevard South, Suite 5560
Las Vegas, NV 89101
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Amos Ben Blackman, WA SBN 50331
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
909 First Avenue, Suite 400
Seattle, WA 98104
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

12
13
14

Attorneys for Defendants (except Defendant Cypress Point Ventures, LLC):

15

Paul M. Ostroff (CSB No. 67054)
[e-mail]
Beth Golub Joffe (Admitted Pro Hac Vice)
[e-mail]
LANE POWELL PC
601 SW Second Avenue, Suite 2100
Portland, Oregon 97204-3158
Telephone: [phone]
Facsimile: 503.778.2200

16
17
18
19
20
21
22
23
24
25
26
27
28

-3STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1

1.

2

PURPOSES AND LIMITATIONS
At the Settlement Conference held before U.S. Magistrate Judge Barbara A. McAuliffe

3

on October 25, 2018, Judge McAuliffe suggested that the disclosure of certain confidential

4

financial information and documents (in accordance with Federal Rule of Evidence 408) would

5

likely be of assistance to the settlement process, notwithstanding that discovery in the above-

6

captioned matter has not yet commenced. Plaintiff U.S. Equal Employment Opportunity

7

Commission (“EEOC”) and Defendants1 (collectively, the “Parties”) have agreed to be bound by

8

the terms of this Stipulated Protective Order for the limited purpose of facilitating the settlement

9

proceedings before Judge McAuliffe, and accordingly, the Parties hereby stipulate to and petition

10

the court to enter the following Stipulated Protective Order.

11

2.

DEFINITIONS
“CONFIDENTIAL” Information or Items:

12

(a) Defendants’ financial information (regardless of how it is generated, stored or

13
14

maintained), including: tax returns (and related documents), audit-related records, financial

15

statements (such as balance sheets, income statements, statement of cash flows), any long-term

16

debt agreements, loan information, monthly receivables/payables (and related details), salaries of

17

persons with ownership interest (direct or indirect), yearly distributions or dividends to anyone

18

with an ownership interest, and related information and documents. The parties agree that such

19

information is also considered confidential information under 5 U.S.C. § 552(b)(4); and

20

(b) Analyses and reports concerning the information described in subparagraph (a).

21
22

Counsel (without qualifier): Outside Counsel of Record and Government Counsel
as defined below (as well as their support staff).

23
24

Designating Party: a Party or Non-Party that designates information or items that
it produces in settlement disclosures as “CONFIDENTIAL.”

25
26

Disclosure Material: all items or information, regardless of the medium or
manner in which it is generated, stored, or maintained (including, among other things, testimony,

27
28
1

“Defendants” refers to all named defendants except Cypress Point Ventures LLC.

-4STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1

transcripts, and tangible things), that are produced or generated in settlement disclosures in this

2

matter.

3

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

4

to the litigation who (1) has been retained by a Party or its counsel to serve as an expert witness

5

or as a consultant in this action, (2) is not a past or current employee of a Party or of a Party’s

6

competitor, and (3) at the time of retention, is not anticipated to become an employee of a Party

7

or of a Party’s competitor.

8
9

Government Counsel: attorneys employed by the United States Equal
Employment Opportunity who have entered an appearance in this action, or whose review is

10

necessary for evaluation and approval of any settlement. Government Counsel does not include

11

Outside Counsel of Record or any other outside counsel.

12
13

Non-Party: any natural person, partnership, corporation, association, or other
legal entity not named as a Party to this action.

14

Outside Counsel of Record: attorneys who are not employees of a party to this

15

action but are retained to represent or advise a party to this action and have appeared in this

16

action on behalf of that party or are affiliated with a law firm which has appeared on behalf of

17

that party.

18

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

19

consultants, retained experts, and Outside Counsel of Record (and their support staffs). For

20

purposes of this Stipulated Protective Order, the undersigned agree that the plaintiff party in this

21

matter is the United States Equal Employment Opportunity Commission, and no other federal or

22

state governmental agency.

23
24
25

Producing Party: a Party or Non-Party that produces Disclosure Material in this
action.
Professional Vendors: persons or entities that provide litigation support services

26

(e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and

27

organizing, storing, or retrieving data in any form or medium) and their employees and

28

subcontractors.

-5STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1

Protected Material: any Disclosure Material that is designated as

2

“CONFIDENTIAL.” The parties agree that such information is also considered confidential

3

information under 5 U.S.C. § 552(b)(4).

4

Receiving Party: a Party that receives Disclosure Material from a Producing

5

Party.

6

3.

7

SCOPE
The protections conferred by this Stipulation and Order cover not only Protected Material

8

(as defined above), but also (1) any information copied or extracted from Protected Material;

9

(2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,

10

conversations, or presentations by Parties or their Counsel that might reveal Protected Material.

11

However, the protections conferred by this Stipulation and Order do not cover the following

12

information: (a) any information that is in the public domain at the time of disclosure to a

13

Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as

14

a result of publication not involving a violation of this Order; and (b) any information known to

15

the Receiving Party prior to the disclosure or obtained by the Receiving Party after the disclosure

16

from a source who obtained the information lawfully and under no obligation of confidentiality

17

to the Designating Party.

18

4.

DURATION

19

Even after final disposition of this litigation, the confidentiality obligations imposed by

20

this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court

21

order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all

22

claims and defenses in this action, with or without prejudice; and (2) final judgment herein after

23

the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this

24

action, including the time limits for filing any motions or applications for extension of time

25

pursuant to applicable law. The term “final judgment” includes, but is not limited to, a judgment

26

or order entered approving a consent decree.

27
28

-6STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1

5.

DESIGNATING PROTECTED MATERIAL

2

Exercise of Restraint and Care in Designating Material for Protection. Each Party

3

or Non-Party that designates information or items for protection under this Order must take care

4

to limit any such designation to specific material that qualifies under the appropriate standards.

5

To the extent it is practical to do so, the Designating Party must designate for protection only

6

those parts of material, documents, items, or oral or written communications that qualify – so

7

that other portions of the material, documents, items, or communications for which protection is

8

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

9

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

10

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

11

Parties that it is withdrawing the mistaken designation.

12

Manner and Timing of Designations. Except as otherwise provided in this Order

13

(see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,

14

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

15

before the material is disclosed or produced.

16

Designation in conformity with this Order requires:

17

(a) for information in documentary form (e.g., paper or electronic documents, but

18

excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing

19

Party affix the legend “CONFIDENTIAL” to each page that contains protected material. If only

20

a portion or portions of the material on a page qualifies for protection, the Producing Party also

21

must clearly identify the protected portion(s) (e.g., by making appropriate markings in the

22

margins).

23

A Party or Non-Party that makes original documents or materials available for inspection

24

need not designate them for protection until after the inspecting Party has indicated which

25

material it would like copied and produced. During the inspection and before the designation, all

26

of the material made available for inspection shall be deemed “CONFIDENTIAL.” After the

27

inspecting Party has identified the documents it wants copied and produced, the Producing Party

28

must determine which documents, or portions thereof, qualify for protection under this Order.

-7STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1

Then, before producing the specified documents, the Producing Party must affix the

2

“CONFIDENTIAL” legend to each page that contains Protected Material. If only a portion or

3

portions of the material on a page qualifies for protection, the Producing Party also must clearly

4

identify the protected portion(s) (e.g., by making appropriate markings in the margins).

5

(b) for information produced in some form other than documentary and for any other

6

tangible items, that the Producing Party affix in a prominent place on the exterior of the

7

container or containers in which the information or item is stored the legend

8

“CONFIDENTIAL.” If only a portion or portions of the information or item warrant protection,

9

the Producing Party, to the extent practicable, shall identify the protected portion(s).

10

Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to

11

designate qualified information or items does not, standing alone, waive the Designating Party’s

12

right to secure protection under this Order for such material. Upon timely correction of a

13

designation, the Receiving Party must make reasonable efforts to assure that the material is

14

treated in accordance with the provisions of this Order.

15

6.

16

CHALLENGING CONFIDENTIALITY DESIGNATIONS
The scope and purpose of this Protective Order is limited to the facilitation of settlement

17

proceedings before Judge McAuliffe, and therefore it should not necessary for any Party to

18

challenge a confidentiality designation. A Party’s disclosure of Protected Material and/or the

19

designation of such material as “CONFIDENTIAL” pursuant to this Order does not prejudice or

20

enhance its or any other Party’s or Non-Party’s rights and obligations with respect to the

21

disclosure or protection of the same material in discovery and/or trial of the above-captioned

22

action.

23

7.

ACCESS TO AND USE OF PROTECTED MATERIAL FOR SETTLEMENT ONLY

24

Basic Principles. A Receiving Party may use Protected Material that is disclosed

25

or produced by another Party or by a Non-Party in connection with this case only for attempting

26

to settle this litigation. Such Protected Material may be disclosed only to the categories of

27

persons and under the conditions described in this Order. When the litigation has been

28

terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL

-8STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1

DISPOSITION).

2
3

Protected Material must be stored and maintained by a Receiving Party at a location and
in a secure manner2 that ensures that access is limited to the persons authorized under this Order.
Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

4
5

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

6

disclose any information or item designated “CONFIDENTIAL” only to:
(a) the Receiving Party’s Outside Counsel of Record in this action, as well as

7
8

employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the

9

information for this litigation and who have signed the “Acknowledgment and Agreement to Be

10

Bound” that is attached hereto as Exhibit A;

11
12

(b) Government Counsel (and support staff) to whom it is reasonably necessary to
disclose the information for this litigation;

13

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

14

reasonably necessary for this litigation and who have signed the “Acknowledgment and

15

Agreement to Be Bound” (Exhibit A);

16

(d) the court and its personnel;

17

(e) Professional Vendors to whom disclosure is reasonably necessary for this

18

litigation and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

19

(f) the author or recipient of a document containing the information or a custodian or

20

other person who otherwise possessed or knew the information.

21

8.

PROTECTED MATERIAL SUBJECT TO A PUBLIC RECORDS REQUEST, A

22

FREEDOM OF INFORMATION ACT REQUEST, SUBPOENAED OR ORDERED

23

PRODUCED IN OTHER LITIGATION

24

If a Party is served with a public records request, a request pursuant to Freedom of

25

Information Act (5 U.S.C. § 552), a subpoena, or a court order issued in other litigation that

26
27
2

It may be appropriate under certain circumstances to require the Receiving Party to store any electronic Protected

28
Material in password-protected form.

-9STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1

compels disclosure of any information or items designated in this action as “CONFIDENTIAL,”

2

that Party must:

3
4

(a) promptly notify in writing the Designating Party. Such notification shall include a
copy of the request, subpoena or court order;

5

(b) promptly notify in writing the party who caused the request, subpoena, or order to

6

issue in the other litigation that some or all of the material covered by the subpoena or order is

7

subject to this Protective Order. Such notification shall include a copy of this Stipulated

8

Protective Order; and

9

(c) cooperate with respect to all reasonable procedures sought to be pursued by the

10

Designating Party whose Protected Material may be affected, which includes (where applicable)

11

asserting that such Protected Material is exempt from disclosure pursuant to 5 U.S.C. § 552(b)(4)

12

or other applicable law.3

13

If the Designating Party timely seeks a protective order, the Party served with the

14

subpoena or court order shall not produce any information designated in this action as

15

“CONFIDENTIAL” before a determination by the court from which the subpoena or order

16

issued, unless the Party has obtained the Designating Party’s permission. The Designating Party

17

shall bear the burden and expense of seeking protection in that court of its confidential material –

18

and nothing in these provisions should be construed as authorizing or encouraging a Receiving

19

Party in this action to disobey a lawful directive from another court.

20

9.

21

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
LITIGATION

22

(a) The terms of this Order are applicable to information produced by a Non-Party in

23

this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in

24

connection with this litigation is protected by the remedies and relief provided by this Order.

25
26
3

The purpose of imposing these duties is to alert the interested parties to the existence of this Protective Order and

27
to afford the Designating Party in this case an opportunity to try to protect its confidentiality interests in the court

28
from which the subpoena or order issued.

-10STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1

Nothing in these provisions should be construed as prohibiting a Non-Party from seeking

2

additional protections.

3

(b) In the event that a Party is required, by a valid request, to produce a Non-Party’s

4

confidential information in its possession, and the Party is subject to an agreement with the Non-

5

Party not to produce the Non-Party’s confidential information, then the Party shall:

6

(1)

promptly notify in writing the Requesting Party and the Non-Party that

7

some or all of the information requested is subject to a confidentiality agreement with a Non-

8

Party;

9

(2)

promptly provide the Non-Party with a copy of the Stipulated Protective

10

Order in this litigation, the relevant request(s), and a reasonably specific description of the

11

information requested; and

12

(3)

13

make the information requested available for inspection by the Non-Party.

(c) If the Non-Party fails to object or seek a protective order from this court within 14

14

days of receiving the notice and accompanying information, the Receiving Party may produce

15

the Non-Party’s confidential information responsive to the request. If the Non-Party timely

16

seeks a protective order, the Receiving Party shall not produce any information in its possession

17

or control that is subject to the confidentiality agreement with the Non-Party before a

18

determination by the court. Absent a court order to the contrary, the Non-Party shall bear the

19

burden and expense of seeking protection in this court of its Protected Material.

20

10.

21

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

22

Material to any person or in any circumstance not authorized under this Stipulated Protective

23

Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the

24

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

25

Protected Material, (c) inform the person or persons to whom unauthorized disclosures were

26

made of all the terms of this Order, and (d) request such person or persons to execute the

27

“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A.

28

-11STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1

11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED

2

MATERIAL

3

When a Producing Party gives notice to Receiving Parties that certain inadvertently

4

produced material is subject to a claim of privilege or other protection, the obligations of the

5

Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This

6

provision is not intended to modify whatever procedure may be established in an e-discovery

7

order that provides for production without prior privilege review. Pursuant to Federal Rule of

8

Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a

9

communication or information covered by the attorney-client privilege or work product

10

protection, the parties may incorporate their agreement in the stipulated protective order

11

submitted to the court.

12

12.

13
14
15

MISCELLANEOUS
Right to Further Relief. Nothing in this Order abridges the right of any person

to seek its modification by the court in the future.
Right to Assert Other Objections. By stipulating to the entry of this Protective

16

Order no Party waives any right it otherwise would have to object to disclosing or producing any

17

information or item on any ground not addressed in this Stipulated Protective Order. Similarly,

18

no Party waives any right to object on any ground to use in evidence of any of the material

19

covered by this Protective Order.

20

Filing Protected Material. The Parties agree that they will not file in the public

21

record in this action any Protected Material disclosed or produced under this Protective Order,

22

because as established under paragraph 7, use of Protected Material is limited to attempting to

23

settle this litigation.

24

No Effect Outside the Settlement Proceedings and/or on Discovery. Nothing

25

in this Order prejudices nor enhances the right or obligation of any Party to seek the same,

26

similar, or related information outside the settlement proceedings; the right or obligation of any

27

Party to object to such discovery; the right or obligation of any Party to move for a protective

28

order regarding such discovery; and/or the right or obligation of any Party to object to, oppose,

-12STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1

or challenge a motion for a protective order and/or a confidentiality designation made outside the

2

settlement proceedings.

3

13.

4

FINAL DISPOSITION
Following the earlier of: (1) final disposition of this action, as defined in paragraph 4, (2)

5

settlement of this action, or (3) three months after the completion of the settlement conference, as

6

determined by Judge McAuliffe, Counsel must destroy and/or return all Protected Material.

7

Notwithstanding this provision, Counsel are entitled to retain archival copies where necessary,

8

including, in the case of the EEOC, as required in accordance with the National Archives and

9

Records Administration (NARA) statutes and regulations. Any such archival copies that contain

10

or constitute Protected Material remain subject to this Protective Order as set forth in Section 4

11

(DURATION).

12
13

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

14
15

DATED:

December 12, 2018

16

/s/Amos B. Blackman
Attorneys for Plaintiff

17
18
19

DATED:

December 12, 2018
Attorneys for Defendants

20
21
22
23
24
25
26
27
28

-13STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

I,

[print or type full name], of

4

[print or type full address],

5

declare under penalty of perjury that I have read in its entirety and understand the Stipulated

6

Protective Order that was issued by the United States District Court for the Eastern District of

7

California on

8

1:17-cv-01299-AWI-SAB. I agree to comply with and to be bound by all the terms of this

9

Stipulated Protective Order and I understand and acknowledge that failure to so comply could

in the case of EEOC v. Prestige Care, Inc. et al., Case No.

10

expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will

11

not disclose in any manner any information or item that is subject to this Stipulated Protective

12

Order to any person or entity except in strict compliance with the provisions of this Order.

13

I further agree to submit to the jurisdiction of the United States District Court for the Eastern

14

District of California for the purpose of enforcing the terms of this Stipulated Protective Order,

15

even if such enforcement proceedings occur after termination of this action.

16

I hereby appoint

[print or type full name] of

17

[print or type full address

18

and telephone number] as my California agent for service of process in connection with this

19

action or any proceedings related to enforcement of this Stipulated Protective Order.

20
21

Date:

22

City and State where sworn and signed:

23
24

Printed name:

25
26

Signature:

27
28

-14STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES

1
2
3

ORDER
Following review, the Court HEREBY ADOPTS the Stipulated Protective Order for
Settlement Disclosures submitted by the parties.

4
5
6
7

IT IS SO ORDERED.
Dated:

December 27, 2018

/s/ Barbara

A. McAuliffe

_

UNITED STATES MAGISTRATE JUDGE

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

-15STIPULATED PROTECTIVE ORDER FOR SETTLEMENT DISCLOSURES