Roberson v. Saputo Cheese USA, Inc.

Filing 12

PROTECTIVE ORDER signed by Magistrate Judge Barbara A. McAuliffe on 7/3/2024. (Lundstrom, T)

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1 2 3 4 Manny Starr (319778) manny@frontierlawcenter.com FRONTIER LAW CENTER 23901 Calabasas Road, Suite 1084 Calabasas, CA 91302 Telephone: (818) 914-3433 Facsimile: (818) 914-3433 5 Attorneys for Plaintiff FLOYD EDWARD ROBERSON 6 7 8 9 10 S. BRETT SUTTON 143107 JARED HAGUE 251517 TRAVIS HODGKINS 262063 SUTTON HAGUE LAW CORPORATION, P.C. 5200 N. Palm Ave., Ste. 203 Fresno, California 93704 Telephone: (559) 325-0500 Facsimile: (559) 981-1217 11 Attorneys for Defendant SAPUTO CHEESE USA, INC. 12 13 UNITED STATES DISTRICT COURT 14 FOR THE EASTERN DISTRICT OF CALIFORNIA 15 16 17 18 19 20 21 Case No. 1:24-cv-00175-KES-BAM FLOYD EDWARD ROBERSON, STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER Plaintiff, v. SAPUTO CHEESE USA, INC.; and DOES 1 through 100, Defendant. 22 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 1 1. PURPOSES AND LIMITATIONS Disclosure and discovery activity in this action are likely to involve production of 2 3 confidential, proprietary, or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, 5 the parties hereby stipulate to and petition the court to enter the following Stipulated Protective 6 Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures 7 or responses to discovery and that the protection it affords from public disclosure and use extends 8 only to the limited information or items that are entitled to confidential treatment under the 9 applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, below, that 10 this Stipulated Protective Order does not entitle them to file confidential information under seal; 11 Local Rule 141 sets forth the procedures that must be followed and the standards that will be applied 12 when a party seeks permission from the court to file material under seal. 13 2. 14 15 16 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 17 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of 18 Civil Procedure 26(c). 19 20 21 22 23 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 24 or manner in which it is generated, stored, or maintained (including, among other things, testimony, 25 transcripts, and tangible things), that are produced or generated in disclosures or responses to 26 discovery in this matter. 27 28 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to the 2 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 1 litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 2 consultant in this action. 2.7 3 4 does not include Outside Counsel of Record or any other outside counsel. 2.8 5 6 House Counsel: attorneys who are employees of a party to this action. House Counsel Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.9 7 Outside Counsel of Record: attorneys who are not employees of a party to this action 8 but are retained to represent or advise a party to this action and have appeared in this action on 9 behalf of that party or are affiliated with a law firm which has appeared on behalf of that party. 2.10 10 11 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 2.11 12 13 Party: any party to this action, including all of its officers, directors, employees, Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action. 2.12 14 Professional Vendors: persons or entities that provide litigation support services (e.g., 15 photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, 16 storing, or retrieving data in any form or medium) and their employees and subcontractors. 2.13 17 18 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 2.14 19 Receiving Party: a Party that receives Disclosure or Discovery Material from a 20 Producing Party. 21 3. 22 SCOPE The protections conferred by this Stipulation and Order cover not only Protected Material (as 23 defined above), but also (1) any information copied or extracted from Protected Material; (2) all 24 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 25 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 26 However, the protections conferred by this Stipulation and Order do not cover the following 27 information: (a) any information that is in the public domain at the time of disclosure to a Receiving 28 3 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 1 Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of 2 publication not involving a violation of this Order, including becoming part of the public record 3 through trial or otherwise; and (b) any information known to the Receiving Party prior to the 4 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 5 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of 6 Protected Material at trial shall be governed by a separate agreement or order. 7 4. Even after final disposition of this litigation, the confidentiality obligations imposed by this 8 9 DURATION Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order 10 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and 11 defenses in this action, with or without prejudice; and (2) final judgment herein after the completion 12 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the 13 time limits for filing any motions or applications for extension of time pursuant to applicable law. 14 5. 15 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or 16 Non-Party that designates information or items for protection under this Order must take care to 17 limit any such designation to specific material that qualifies under the appropriate standards. The 18 Designating Party must designate for protection only those parts of material, documents, items, or 19 oral or written communications that qualify – so that other portions of the material, documents, 20 items, or communications for which protection is not warranted are not swept unjustifiably within 21 the ambit of this Order. 22 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown 23 to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily 24 encumber or retard the case development process or to impose unnecessary expenses and burdens on 25 other parties) expose the Designating Party to sanctions. 26 27 28 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 4 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 1 2 that it is withdrawing the mistaken designation. 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see, 3 e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 4 Discovery Material that qualifies for protection under this Order must be clearly so designated 5 before the material is disclosed or produced. 6 7 Designation in conformity with this Order requires: (a) For information in documentary form (e.g., paper or electronic documents, but 8 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 9 affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a portion 10 or portions of the material on a page qualifies for protection, the Producing Party also must clearly 11 identify the protected portion(s) (e.g., by making appropriate markings in the margins). 12 A Party or Non-Party that makes original documents or materials available for inspection need not 13 designate them for protection until after the inspecting Party has indicated which material it would 14 like copied and produced. During the inspection and before the designation, all of the material made 15 available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 16 identified the documents it wants copied and produced, the Producing Party must determine which 17 documents, or portions thereof, qualify for protection under this Order. Then, before producing the 18 specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page 19 that contains Protected Material. If only a portion or portions of the material on a page qualifies for 20 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making 21 appropriate markings in the margins). 22 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the 23 Designating Party identify on the record, before the close of the deposition, hearing, or other 24 proceeding, all protected testimony. 25 (c) for information produced in some form other than documentary and for any other 26 tangible items, that the Producing Party affix in a prominent place on the exterior of the container or 27 containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a 28 5 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 1 portion or portions of the information or item warrant protection, the Producing Party, to the extent 2 practicable, shall identify the protected portion(s). 5.3 3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 4 designate qualified information or items does not, standing alone, waive the Designating Party’s 5 right to secure protection under this Order for such material. Upon timely correction of a 6 designation, the Receiving Party must make reasonable efforts to assure that the material is treated in 7 accordance with the provisions of this Order. 8 6. 9 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 10 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 11 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, 12 or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a 13 confidentiality designation by electing not to mount a challenge promptly after the original 14 designation is disclosed. 15 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process 16 by providing written notice of each designation it is challenging and describing the basis for each 17 challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must 18 recite that the challenge to confidentiality is being made in accordance with this specific paragraph 19 of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must 20 begin the process by conferring directly (in voice to voice dialogue; other forms of communication 21 are not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging 22 Party must explain the basis for its belief that the confidentiality designation was not proper and 23 must give the Designating Party an opportunity to review the designated material, to reconsider the 24 circumstances, and, if no change in designation is offered, to explain the basis for the chosen 25 designation. A Challenging Party may proceed to the next stage of the challenge process only if it 26 has engaged in this meet and confer process first or establishes that the Designating Party is 27 unwilling to participate in the meet and confer process in a timely manner. 28 6 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 6.3 1 Judicial Intervention. If the Parties cannot resolve a challenge without court 2 intervention, the Designating Party shall file and serve a motion to retain confidentiality under Civil 3 Local Rule 230 (and in compliance with Local Rule 141.1, if applicable) within 21 days of the initial 4 notice of challenge or within 14 days of the parties agreeing that the meet and confer process will not 5 resolve their dispute, whichever is earlier. Each such motion must be accompanied by a competent 6 declaration affirming that the movant has complied with the meet and confer requirements imposed 7 in the preceding paragraph. Failure by the Designating Party to make such a motion including the 8 required declaration within 21 days (or 14 days, if applicable) shall automatically waive the 9 confidentiality designation for each challenged designation. In addition, the Challenging Party may 10 file a motion challenging a confidentiality designation at any time if there is good cause for doing so, 11 including a challenge to the designation of a deposition transcript or any portions thereof. Any 12 motion brought pursuant to this provision must be accompanied by a competent declaration 13 affirming that the movant has complied with the meet and confer requirements imposed by the 14 preceding paragraph. 15 The burden of persuasion in any such challenge proceeding shall be on the Designating 16 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose 17 unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions. 18 Unless the Designating Party has waived the confidentiality designation by failing to file a motion to 19 retain confidentiality as described above, all parties shall continue to afford the material in question 20 the level of protection to which it is entitled under the Producing Party’s designation until the court 21 rules on the challenge. 22 7. 23 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 24 produced by another Party or by a Non-Party in connection with this case only for prosecuting, 25 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to 26 the categories of persons and under the conditions described in this Order. When the litigation has 27 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL 28 7 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 1 2 3 4 DISPOSITION). 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 5 the court or permitted in writing by the Designating Party, a Receiving Party may disclose any 6 information or item designated “CONFIDENTIAL” only to: 7 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees 8 of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for 9 this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” that is 10 11 attached hereto as Exhibit A; (b) the officers, directors, and employees (including House Counsel) of the Receiving 12 Party to whom disclosure is reasonably necessary for this litigation and who have signed the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 15 reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement 16 to Be Bound” (Exhibit A); 17 (d) the court and its personnel; 18 (e) court reporters and their staff, professional jury or trial consultants, mock jurors, and 19 Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have 20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (f) during their depositions, witnesses in the action to whom disclosure is reasonably 22 necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 23 unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed 24 deposition testimony or exhibits to depositions that reveal Protected Material must be separately 25 bound by the court reporter and may not be disclosed to anyone except as permitted under this 26 Stipulated Protective Order. 27 28 (g) the author or recipient of a document containing the information or a custodian or 8 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 1 other person who otherwise possessed or knew the information. 2 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 3 LITIGATION 4 If a Party is served with a subpoena or a court order issued in other litigation that compels 5 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party 6 must: (a) promptly notify in writing the Designating Party. Such notification shall include a 7 8 copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order to issue in the 9 10 other litigation that some or all of the material covered by the subpoena or order is subject to this 11 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 12 13 Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with the subpoena 14 15 or court order shall not produce any information designated in this action as “CONFIDENTIAL” 16 before a determination by the court from which the subpoena or order issued, unless the Party has 17 obtained the Designating Party’s permission. The Designating Party shall bear the burden and 18 expense of seeking protection in that court of its confidential material – and nothing in these 19 provisions should be construed as authorizing or encouraging a Receiving Party in this action to 20 disobey a lawful directive from another court. 21 9. 22 23 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 24 action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in 25 connection with this litigation is protected by the remedies and relief provided by this Order. 26 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional 27 protections. 28 9 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 1 (b) In the event that a Party is required, by a valid discovery request, to produce a Non- 2 Party’s confidential information in its possession, and the Party is subject to an agreement with the 3 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 4 5 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 6 7 this litigation, the relevant discovery request(s), and a reasonably specific description of the 8 information requested; and 9 (3) make the information requested available for inspection by the Non-Party. 10 (c) If the Non-Party fails to object or seek a protective order from this court within 14 11 days of receiving the notice and accompanying information, the Receiving Party may produce the 12 Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely 13 seeks a protective order, the Receiving Party shall not produce any information in its possession or 14 control that is subject to the confidentiality agreement with the Non-Party before a determination by 15 the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of 16 seeking protection in this court of its Protected Material. 17 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 18 19 Material to any person or in any circumstance not authorized under this Stipulated Protective Order, 20 the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized 21 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) 22 inform the person or persons to whom unauthorized disclosures were made of all the terms of this 23 Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to 24 Be Bound” that is attached hereto as Exhibit A. 25 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 26 MATERIAL 27 When a Producing Party gives notice to Receiving Parties that certain inadvertently produced 28 10 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 1 material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties 2 are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to 3 modify whatever procedure may be established in an e-discovery order that provides for production 4 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 5 parties reach an agreement on the effect of disclosure of a communication or information covered by 6 the attorney-client privilege or work product protection, the parties may incorporate their agreement 7 in the stipulated protective order submitted to the court. 8 12. 12.1 9 10 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. 12.2 11 Right to Assert Other Objections. By stipulating to the entry of this Protective Order 12 no Party waives any right it otherwise would have to object to disclosing or producing any 13 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 14 Party waives any right to object on any ground to use in evidence of any of the material covered by 15 this Protective Order. 12.3 16 Filing Protected Material. Without written permission from the Designating Party or a 17 court order secured after appropriate notice to all interested persons, a Party may not file in the 18 public record in this action any Protected Material. A Party that seeks to file under seal any Protected 19 Material must comply with Local Rule 141. Protected Material may only be filed under seal pursuant 20 to a court order authorizing the sealing of the specific Protected Material at issue. Pursuant to Local 21 Rule 141, a sealing order will issue only upon a request establishing that the Protected Material at 22 issue is privileged, protectable as a trade secret, or otherwise entitled to protection under the law. If a 23 Receiving Party's request to file Protected Material under seal pursuant to Local Rule 141 is denied 24 by the court, then the Receiving Party may file the information in the public record pursuant to Local 25 Rule 141 unless otherwise instructed by the court. 26 13. 27 28 FINAL DISPOSITION Within 60 days after the final disposition of this action, as defined in paragraph 4, each 11 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 1 Receiving Party must return all Protected Material to the Producing Party or destroy such material. 2 As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 3 summaries, and any other format reproducing or capturing any of the Protected Material. Whether 4 the Protected Material is returned or destroyed, the Receiving Party must submit a written 5 certification to the Producing Party (and, if not the same person or entity, to the Designating Party) 6 by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected Material 7 that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, 8 abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected 9 Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 10 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 11 correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant 12 and expert work product, even if such materials contain Protected Material. Any such archival copies 13 that contain or constitute Protected Material remain subject to this Protective Order as set forth in 14 Section 4 (DURATION). 15 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 16 17 DATED: 7/2/04 /s/ Manny Starr MANNY STARR Attorney for Plaintiff DATED: 7/2/04 /s/ S. Brett Sutton S. BRETT SUTTON Attorney for Defendant 18 19 20 21 22 23 24 25 26 27 28 12 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of _________________ [print or 4 type full address], declare under penalty of perjury that I have read in its entirety and understand the 5 Stipulated Protective Order that was issued by the United States District Court for the Eastern 6 District of California on [date] in the case of Roberson v. Saputo Cheese USA, Inc., Case No. 1:24- 7 cv-00175-KES-BAM. I agree to comply with and to be bound by all the terms of this Stipulated 8 Protective Order and I understand and acknowledge that failure to so comply could expose me to 9 sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in 10 any manner any information or item that is subject to this Stipulated Protective Order to any person 11 or entity except in strict compliance with the provisions of this Order. 12 I further agree to submit to the jurisdiction of the United States District Court for the Eastern District 13 of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such 14 enforcement proceedings occur after termination of this action. 15 I hereby appoint __________________________ [print or type full name] of 16 _______________________________________ [print or type full address and telephone number] as 17 my California agent for service of process in connection with this action or any proceedings related 18 to enforcement of this Stipulated Protective Order. 19 20 Date: ______________________________________ 21 City and State where sworn and signed: _________________________________ 22 23 Printed name: _______________________________ 24 25 Signature: __________________________________ 26 27 28 13 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER ORDER 1 2 3 4 Having considered the parties’ stipulated protective order, and finding good cause, the Court adopts the stipulated protective order (Doc. 11). The parties are advised that pursuant to the Local Rules of the United States District Court, 5 Eastern District of California, any documents subject to the protective order to be filed under seal 6 must be accompanied by a written request which complies with Local Rule 141 prior to sealing. The 7 party making a request to file documents under seal shall be required to show good cause for 8 documents attached to a non-dispositive motion or compelling reasons for documents attached to a 9 dispositive motion. Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-78 (9th Cir. 2009). Within 10 five (5) days of any approved document filed under seal, the party shall file a redacted copy of the 11 sealed document. The redactions shall be narrowly tailored to protect only the information that is 12 confidential or was deemed confidential. 13 14 Additionally, the parties shall consider resolving any dispute arising under the stipulated protective order according to the Court’s informal discovery dispute procedure. 15 16 17 18 IT IS SO ORDERED. Dated: July 3, 2024 /s/ Barbara A. McAuliffe UNITED STATES MAGISTRATE JUDGE 19 20 21 22 23 24 25 26 27 28 _ 14 STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER

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