Boyd v. Walmart

Filing 10

STIPULATION and ORDER signed by Magistrate Judge Jeremy D. Peterson on 5/8/24 Regarding Production of Confidential Documents and Proprietary Information. (Kastilahn, A)

Download PDF
Narak Mirzaie, SBN 311508 2 M LAW ATTORNEYS, APC 680 East Colorado Blvd., Suite 180 3 Pasadena, CA 91101 Telephone: 626-626-4422 4 Facsimile: 626-626-4420 1 5 Attorney for DIANE BOYD 6 11 JAMES T. CONLEY, SBN 224174 JANE A. ROTHBALER, SBN 201755 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 400 Capitol Mall, Suite 2800 Sacramento, CA 95814 Telephone: 916-840-3150 Facsimile: 916-840-3159 12 Attorneys for WALMART INC. 7 8 9 10 13 UNITED STATES DISTRICT COURT 14 EASTERN DISTRICT OF CALIFORNIA 15 16 DIANE L. BOYD, an individual; 17 Plaintiff, 18 Case No. 2:24-cv-00275-DJC-JDP STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION AND ORDER vs. WALMART; A Corporation Doing Business in California; and DOES 1 20 through 50, inclusive; 19 21 Defendants. Action Filed: Trial Date: December 18, 2023 None Set 22 23 24 25 26 27 28 1 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 1 IT IS HEREBY STIPULATED by and between Plaintiff BOYD (“Plaintiff”) 2 and Defendant WALMART INC. (“Defendant”) (collectively, “the Parties”), through 3 their respective attorneys of record, that a Protective Order be entered by this Court as 4 follows: 5 1. This Stipulation and Protective Order shall apply to the production and 6 exchange of all document requests and documents, interrogatories and answers to 7 interrogatories, depositions, request for admissions and responses to requests for 8 admissions, exhibits, pleadings, admission of evidence at trial, and all other 9 information exchanged and furnished in this action by the Parties that are confidential 10 11 and/or proprietary. 2. The Parties acknowledge that discovery will require disclosure of 12 information that is private, personal, privileged, confidential, proprietary, or 13 nonpublic. As a result, the Parties agree that they will be required to enter this 14 Stipulation and Protective Order (hereinafter “Order”) on the following terms to 15 ensure the continuing confidentiality of materials designated as Confidential Material 16 in this litigation. Confidential Material, as used in this Order, shall refer to any 17 document or item designated as “Confidential” or “Highly Confidential – Attorneys’ 18 Eyes Only”. The Parties understand that this Order does not confer blanket protections 19 on all disclosures or responses to discovery and that the protection it affords extends 20 only to the limited information or items that are entitled under the applicable legal 21 principles to treatment as confidential. Nothing in this Order shall require any party to 22 produce any specific document or category of documents which a party deems 23 inappropriate for production. 24 I. Definitions of Confidential Material 25 3. Confidential Material, as used in this Order, consists of the following 26 27 28 materials and categories of materials: (a) Materials relating to any privileged, confidential, or nonpublic information, including, but not limited to, trade secrets, research, design, 2 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 1 development, financial, technical, marketing, planning, personal, or commercial 2 information, as such terms are used in the Federal Rules of Civil Procedure and 3 any applicable case law interpreting Federal Rule of Civil Procedure 4 26(c)(1)(G), contracts, non-public compilations of retail prices; proprietary 5 information, vendor agreements; personnel files; claim/litigation information; 6 nonpublic policies and procedures; medical records; employment offers; 7 competitive analyses, income statements; client or customer information; 8 financial records and statements; vendor agreements, along with other 9 proprietary or confidential information. (b) 10 Materials containing corporate trade secrets, nonpublic research 11 and development data, including, but not limited to, cost data, pricing formulas, 12 inventory management programs, and other sales or business information 13 known to the public; information obtained from a non-party pursuant to a non- 14 disclosure agreement; and customer-related Protected Data shall be deemed 15 “Highly Confidential – Attorneys’ Eyes Only”. (c) 16 “Protected Data” shall refer to any information that a party believes 17 in good faith to be subject to federal, state or foreign data protection laws or 18 other privacy obligations. Examples of such data protection laws include but are 19 not limited to The Gramm-Leach-Bliley Act, 15 U.S.C. § 6801 et seq. (financial 20 information); and, The Health Insurance Portability and Accountability Act and 21 the regulations thereunder, 45 CFR Part 160 and Subparts A and E of Part 164 22 (medical information). Certain Protected Data may compel alternative or 23 additional protections beyond those afforded “Highly Confidential – Attorneys’ 24 Eyes Only” material, in which event the Parties shall meet and confer in good 25 faith, and, if unsuccessful, shall move the Court for appropriate relief. 26 4. 27 28 The Parties shall not designate as confidential information that is already public knowledge. 5. The Parties agree that such Confidential Material as described in 3 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 1 paragraph 3 above, should be given the protection of an order of this Court to prevent 2 injury through disclosure to persons other than those persons involved in the 3 prosecution or defense of this litigation. A Protective Order will serve to achieve the 4 following: expedite the flow of information, facilitate the prompt resolution of disputes 5 over confidentiality of discovery materials, adequately protect information the Parties 6 are entitled to keep confidential, ensure that the Parties are permitted reasonable 7 necessary uses of such material in preparation for and in the conduct of trial, and 8 address their handling at the end of the litigation. 9 II. Procedure for Designating Information as Confidential 10 6. To designate information as confidential, the producing party shall mark 11 Confidential Material with the legend “CONFIDENTIAL” or “HIGHLY 12 CONFIDENTIAL – ATTORNEYS’ EYES ONLY”. Parties shall submit confidential 13 discovery responses, such as answers to interrogatories or answers to requests for 14 admissions, in a separate document stamped with the appropriate legend designating 15 those responses as Confidential Material. The Receiving Party may make copies of 16 Confidential Material and such copies shall become subject to the same protections as 17 the Confidential Material from which those copies were made. 18 (a) Information on a disk or other electronic format (e.g., a native format 19 production) may be designated confidential by marking the storage medium itself (or 20 the native file’s title) with the legend “CONFIDENTIAL” or “HIGHLY 21 CONFIDENTIAL – ATTORNEYS’ EYES ONLY”. The Receiving Party shall mark 22 any hard-copy printouts and the storage medium of any permissible copies of such 23 electronic material with the corresponding legend contained on the original and such 24 copies shall become subject to the same protections, as the Confidential Material from 25 which those copies were made. 26 (b) Information disclosed at any deposition of a party taken in this action may 27 be designated by the party as confidential by indicating on the record at the deposition 28 that the information is confidential and subject to the provisions of this Order. 4 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 1 Alternatively, the party may designate information disclosed at the deposition as 2 confidential by notifying the court reporter and other parties in writing, within fifteen 3 (15) business days of receipt of the transcript, of the specific pages and lines of the 4 transcript which are designated as confidential. The Parties may agree to a reasonable 5 extension of the 15-business-day period for designation. Designations of transcripts 6 will apply to audio, video, or other recordings of the testimony. During such 15- 7 business-day period, the entire transcript shall receive confidential treatment. Upon 8 such designation, the court reporter and each party shall affix the “CONFIDENTIAL” 9 or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” legend to the 10 11 designated pages and segregate them as appropriate. 7. A producing party may change the confidentiality designation of 12 materials it has produced, as follows: (1) The producing party must give the receiving 13 parties notice of the change by identifying the documents or information at issue. Once 14 notice is given, the receiving party must make good-faith efforts to ensure that the 15 documents or information are accorded treatment under the new designation. (2) 16 Within a reasonable period after giving notice, the producing party must reproduce the 17 documents or information in a format that contains the new designation. (3) If such 18 information has been disclosed to persons not qualified pursuant to paragraph(s) (14- 19 15) below, the party who disclosed such information shall (a) take reasonable efforts 20 to retrieve previously disclosed Confidential Material; (b) advise such persons that the 21 material is Confidential; and (c) give the producing party written assurance that steps 22 (a) and (b) have been completed. 23 III. Data Security 24 8. The Parties agree to provide adequate security to protect data produced 25 by the other party(ies) or by non-parties. This includes secure data storage systems, 26 established security policies, and security training for employees, contractors and 27 experts. Adequate security also includes such measures as data encryption in transit, 28 data encryption at rest, data access controls, and physical security, whether 5 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 1 hosted/outsourced to a vendor or on premises. At a minimum, any receiving party 2 subject to the terms of this Order, will provide reasonable measures to protect non- 3 client data consistent with the American Bar Association Standing Committee on 4 Ethics and Professional Responsibility, Formal Opinion 477R. 5 IV. Clawback Provisions 6 9. The production of privileged or work-product protected documents, 7 electronically stored information (ESI) or information, whether inadvertent or 8 otherwise, is not a waiver of the privilege or protection from discovery in this case or 9 in any other federal or state proceeding. 10 10. This Order shall be interpreted to provide the maximum protection 11 allowed by Federal Rule of Evidence (FRE) 502(d) and shall be enforceable and 12 granted full faith and credit in all other state and federal proceedings by 28 U.S. Code 13 § 1738. In the event of any subsequent conflict of law, the law that is most protective 14 of privilege and work product shall apply. 15 11. Nothing contained herein is intended to or shall serve to limit a party’s 16 right to conduct a review of documents, ESI or information (including metadata) for 17 relevance, responsiveness and/or segregation of privileged and/or protected 18 information before production. 19 12. If the receiving party has reason to believe that a produced document or 20 other information may reasonably be subject to a claim of privilege, then the receiving 21 party shall immediately sequester the document or information, cease using the 22 document or information and cease using any work product containing the 23 information, and shall inform the producing party of the beginning BATES number of 24 the document or, if no BATES number is available, shall otherwise inform the 25 producing party of the information. 26 13. A producing party must give written notice to any receiving party 27 asserting a claim of privilege, work-product protection, or other ground for reclaiming 28 documents or information (a “clawback request”). After a clawback request is 6 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 1 received, the receiving party shall immediately sequester the document (if not already 2 sequestered) and shall not review or use that document, or any work product 3 containing information taken from that document, for any purpose. The Parties shall 4 meet and confer regarding any clawback request. 5 V. Who May Receive Confidential and Highly Confidential Information 6 14. Confidential Material. Any Confidential Material and the information 7 contained therein shall be disclosed only to the Court, its staff, in-house counsel and 8 outside counsel of record for each party, and also shall be disclosed on a need-to-know 9 basis only to the Parties, counsel’s staff personnel, employees of a party to whom 10 disclosure is necessary in connection with the preparation for and trial of this action, 11 and any witnesses in the case (including consulting and testifying experts) as may from 12 time to time reasonably be necessary in prosecution or defense of this action. 13 15. Highly Confidential—Attorneys’ Eyes Only Material. Material and 14 information designated as “Highly Confidential—Attorneys’ Eyes Only” shall only be 15 disclosed to the Court, its staff, in-house and outside counsel of record for each party, 16 the secretarial, clerical, and paralegal staff of each, and consulting and testifying 17 experts retained by a party in this action. 18 16. Restriction on Disclosure to Direct Competitors. Notwithstanding the 19 foregoing, Confidential Material shall not be disclosed to any current or former 20 employees of, or current or former consultants, advisors, or agents of, a direct 21 competitor of any party named in the litigation. If a Receiving Party is in doubt about 22 whether a particular entity is a direct competitor of a party named in this lawsuit, then 23 before disclosing any Confidential Material to a current or former employee, 24 consultant, advisor, or agent of that entity, the Receiving Party’s counsel must confer 25 with counsel for the Producing Party. 26 17. Persons Receiving Confidential Information Must Sign Exhibit A. 27 Counsel for each party shall advise all persons to whom Confidential Material is 28 disclosed pursuant to this Order of the existence of this Order and shall provide all 7 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 1 such persons (other than the Court and its staff) with a copy of this Order. Counsel 2 shall also require such persons to execute the Affidavit attached as Exhibit A, prior to 3 the disclosure of Confidential Material. 18. 4 Duties in the Event of Unauthorized Disclosures. It shall be the 5 obligation of counsel, upon learning of any unauthorized disclosure or threatened 6 unauthorized disclosure of Confidential Information, or any other breach or threatened 7 breach of the provisions of this Order, to promptly notify counsel for the Producing 8 Party. 9 circumstances of the disclosure in order to permit the producing party to understand 10 and take appropriate steps. Each party and its counsel agree to take reasonable and 11 good-faith efforts to contain or limit any breach promptly upon receiving notice of it, 12 and to make reasonable and good-faith attempts to retrieve any unauthorized 13 disclosure of documents or information. This provision does not limit the producing 14 party’s entitlement to damages resulting from any breach of this Order. The notification shall be supplemented with reasonable details of the 15 VI. Authorized Uses of Confidential Material 16 19. Confidential Material shall only be used for the purpose of litigating the 17 18 above-captioned lawsuit and may not be used in other lawsuits. 20. Persons having knowledge of Confidential Material and information due 19 to their participation in the conduct of this litigation shall use such knowledge and 20 information only as permitted herein, and shall not disclose such Confidential 21 Material, their contents or any portion or summary thereof to any person(s) not 22 involved in the conduct of this litigation. 23 21. If any person having access to the Confidential Material herein shall 24 violate this Order, he/she may be subject to sanctions by the Court and may be liable 25 to pay for the damages caused by his/her violation. 26 VII. Challenges to the Designation of Confidential Material 27 22. 28 Any party or interested member of the public may move the Court to modify the designation of any documents or information produced in this litigation 8 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 1 (either to include additional protection with respect to confidentiality or to remove a 2 confidential designation). Before making such a motion, the party or an interested 3 member of the public shall first attempt to resolve such dispute with the producing 4 party’s counsel. Pending resolution of any challenges to the designation of documents 5 or information, the material at issue shall continue to be treated as Confidential 6 Material until ordered otherwise by the Court. The burden shall be on the party 7 seeking to modify the designation to show that the producing party’s designation is 8 inappropriate. 9 10 VIII. Withholding of Information 23. Redactions. The Parties may redact (1) information that is privileged or 11 protected from discovery as work product or by reason of any other applicable 12 privilege or immunity; (2) information subject to non-disclosure obligations imposed 13 by governmental authorities, law or regulation (e.g., protected personal information); 14 and (3) sensitive, non-relevant information, including but not limited to personally 15 identifiable information, trade secrets, or information regarding products, data, or 16 people. Redactions of emails will not redact the names of recipients or the subject line 17 of the emails, unless the subject line is itself privileged or contains the sensitive 18 information described above, in which case only so much of the subject line will be 19 redacted as may be needed. The Parties will produce redacted documents in TIFF 20 format (or searchable PDF if production format dictates; or in native format for file 21 types that do not convert well to TIFF/PDF, such as Excel files) with corresponding 22 searchable OCR text and the associated metadata for the document, ensuring the 23 redacted content is fully protected from disclosure. 24 IX. Confidential Material In Filings, Hearings, and Trial 25 24. Confidential Material in Filings. Without written permission from the 26 Producing Party or court order secured after appropriate notice to all interested 27 persons, a party may not file Confidential Material in the public record in this action 28 (or in any other action, such as an appeal). A party that seeks to file under seal any 9 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 1 Confidential Material must first obtain a sealing order in compliance with Eastern 2 District of California Local Rule 141. Confidential Material may only be filed under 3 seal in a manner prescribed by the Court for such filings. 4 25. Manner of Sealing. In the event Confidential Materials or portions of 5 transcripts are sealed as confidential by the Court or as described in paragraph (24) 6 above, they shall be filed in an envelope bearing the following designation when 7 deposited: 8 CONFIDENTIAL 9 IN ACCORDANCE WITH THE CONFIDENTIALITY ORDER OF THE 10 COURT, THE CONTENTS OF THIS ENVELOPE SHALL BE TREATED AS 11 CONFIDENTIAL AND MUST NOT BE SHOWN TO A PERSON OTHER THAN 12 THE COURT, ATTORNEYS IN THIS CASE, OR TO PERSONS ASSISTING 13 THOSE ATTORNEYS. 14 26. Confidential Material in Hearings and Trial. The provisions of this 15 Order shall not affect, and this Order does not limit, the admissibility of Confidential 16 Material (or references to that material) as evidence at trial, or during a hearing or 17 similar proceeding in this action. 18 information contained therein at any hearing that is open to the public, the party 19 seeking to use the Confidential Material must give at least seven (7) days advance 20 notice to the producing party of the intent to use the Confidential Material so that the 21 producing party may seek an appropriate Court Order to protect the Confidential 22 Material. 23 X. Continuing Effect of this Order and Duty to Destroy 24 27. This Order shall continue to be binding throughout and after the Prior to using Confidential Material or the 25 conclusion of this litigation, including all appeals. Within thirty (30) days of settlement 26 or final adjudication, including the expiration or exhaustion of all rights to appeal or 27 petitions for extraordinary writs, each party or non-party to whom any materials were 28 produced shall, without further request or direction from the Producing Party, 10 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 1 promptly destroy all documents, items or data received including, but not limited to, 2 copies or summaries thereof, in the possession or control of any expert or employee. 3 This requirement to destroy includes all documents, not only those documents 4 designated as Confidential Material. The Receiving Party shall submit a written 5 certification to the Producing Party by the 30-day deadline that (1) confirms the 6 destruction/deletion of all Confidential Material, including any copies of Confidential 7 Materials provided to persons required to execute Exhibit A (Affidavit), and (2) 8 affirms the Receiving Party has not retained any copies, abstracts, compilations, 9 summaries or any other format reproducing or capturing any of the Confidential 10 Material. Notwithstanding this provision, outside counsel is entitled to retain an 11 archival copy of filings, depositions, and deposition exhibits. 12 XI. Procedure if Confidential Material is Required to be Produced 13 28. If any person receiving documents covered by this Order is served with a 14 subpoena, order, interrogatory, document, or civil investigative demand (collectively, 15 a “Demand”) issued in any other action, investigation, or proceeding, and such 16 Demand seeks material that was produced or designated as Confidential Material by 17 someone other than the Receiving Party, the Receiving Party shall give prompt written 18 notice by hand or electronic transmission within five (5) business days of receipt of 19 such Demand to the party or non-party who produced or designated the material as 20 Confidential Material, and shall object to the production of such materials on the 21 grounds of the existence of this Order. At the request of the party or non-party who 22 produced or designated the material as Confidential Material, the Receiving Party shall 23 refuse to comply with the Demand unless (a) ordered to do so by a court with 24 jurisdiction over the Receiving Party; or (b) released in writing by the party or non- 25 party who designated the material as Confidential Material. The burden of opposing 26 the enforcement of the Demand shall fall upon the party or non-party who produced 27 or designated the material as Confidential Material. Compliance by the Receiving 28 Party with any order of a court of competent jurisdiction, directing production of any 11 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 1 Confidential Material, shall not constitute a violation of this Order. 2 XII. Application of this Order to Productions by Third Parties 3 29. This Order may be used by third parties producing documents in 4 connection with this action. Third parties may designate information as “Confidential” 5 or “Highly Confidential – Attorneys’ Eyes Only”. 6 30. If a third party produces (or intends to produce) documents and does not 7 designate (or does not intend to designate) those documents as Confidential Material, 8 then any party to this action may seek to designate that third party’s documents or 9 categories of documents as Confidential Material. In that case, it will be the burden 10 of the party seeking protected status to move for a court order designating the materials 11 as Confidential Material after the Parties confer. 12 31. In the event additional parties join or intervene in this litigation, the newly 13 joined party(ies) shall not have access to Confidential Material until its/their counsel 14 has executed and, at the request of any party, filed with the Court the agreement of 15 such party(ies) and such counsel to be fully bound by this Order. 16 32. The Parties agree that nothing in this Order shall be deemed to limit the 17 extent to which counsel for the Parties may advise or represent their respective clients, 18 conduct discovery, prepare for trial, present proof at trial, including any document 19 designated Confidential Material as set forth herein, or oppose the production or 20 admissibility of any information or documents which have been requested. 21 22 33. This Order shall remain in full force and effect until such time as it is modified, amended, or rescinded by the Court. 23 XIII. No Admissions 24 34. Neither entering into this Stipulation for Protective Order, nor receiving 25 any documents or other information designated as “Confidential,” shall be construed 26 as an agreement or admission (1) that any document or information designated as 27 “Confidential” is in fact Confidential Information; (2) as to the correctness or truth of 28 any allegation made or position taken relative to any matter designated as 12 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 1 “Confidential”; or (3) as to the authenticity, competency, relevancy, or materiality of 2 any information or document designated as “Confidential.” 3 XIV. Modification – Further Agreements 4 35. Nothing contained herein shall preclude any party from seeking from the 5 Court, modification of this Stipulated Protective Order upon proper notice or shall 6 preclude the Parties from entering into other written agreements designed to protect 7 Confidential Information. 8 XV. Counterparts 9 36. This Stipulation for Protective Order may be executed in counterparts, 10 each of which shall be deemed an original, and which together shall constitute one 11 instrument. 12 13 IT IS SO STIPULATED. 14 15 DATED: April 15, 2024 By: /s/Narak Mirzaie Narak Mirzaie 16 17 Attorneys for Plaintiff DIANE BOYD 18 19 20 21 22 23 M LAW ATTORNEYS, APC DATED: April 15, 2024 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. By: /s/ James T. Conley James T. Conley Jane A. Rothbaler Attorneys for WALMART INC. 24 25 26 27 28 13 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION [PROPOSED] ORDER 1 2 The Court has reviewed the Stipulation Regarding Production of Confidential 3 Documents and Proprietary Information filed by Defendant WALMART INC., 4 (“Defendant”) and Plaintiff DIANE L. BOYD (“Plaintiff”) (collectively “the Parties”), 5 through their counsel of record, requesting that the Court enter an Order. 6 7 IT IS SO ORDERED. 8 Dated: 9 10 May 8, 2024 JEREMY D. PETERSON UNITED STATES MAGISTRATE JUDGE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 14 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION Exhibit A 1 2 ACKNOWLEDGMENT OF RECEIPT OF PROTECTIVE ORDER 3 REGARDING CONFIDENTIAL INFORMATION AND AGREEMENT TO 4 BE BOUND THEREBY 5 I hereby acknowledge receipt of and that I have read a copy of the Stipulation 6 for Protective Order and Order (the “Order”), which I understand was made on 7 _________________, 2024, in the action entitled Diane Boyd v. Walmart Inc., et al., 8 Case No. 2:24-cv-00275-DJC-DMC, USDC, Eastern District of California. I agree 9 that I will be bound by the provisions of the Order with respect to any Confidential 10 Information provided to me under the terms thereof. I agree that, if I receive any 11 Confidential Information, I will not make any copies thereof nor disclose such 12 Confidential Information except as permitted by the Order. I further understand that 13 if I fail to comply with the terms of the Order, I may be subject to sanctions by the 14 Court, and I hereby consent to personal jurisdiction in the State of California with 15 respect to any matter relating to or arising out of the Order. 16 17 Executed this day of 2024, at 18 19 Signature 20 21 22 Name: ________________________________________ Affiliation: ________________________________________ 23 24 25 Address: ________________________________________ ________________________________________ 26 27 28 15 STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION 61651354.v1-OGLETREE

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?