Musa v. Continental Casualty

Filing 23

STIPULATED PROTECTIVE ORDER: Re 21 Proposed Order filed by Continental Casualty Company. Signed by Magistrate Judge Laurel Beeler on 9/20/2016. (lsS, COURT STAFF) (Filed on 9/20/2016)

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1 2 3 4 5 6 7 8 LOUDERBACK LAW GROUP Charles M. Louderback (SBN 88788) 44 Montgomery Street, Suite 2970 San Francisco, CA 94104 Telephone: (415) 615-0200 Facsimile: (415) 233-4775 LAW OFFICES OF JOHN FITZPATRICK VANNUCCI John Fitzpatrick Vannucci (SBN 174329) 1388 Sutter Street, Suite 605 San Francisco, CA 94109 Telephone: (415) 981-7500 Facsimile: (415) 981-5700 9 10 11 12 Attorneys For Plaintiff MICHAEL MUSA SEYFARTH SHAW LLP Camille A. Olson (SBN 111919) Richard B. Lapp (SBN 271052) Joshua Salinas (SBN 282065) 2029 Century Park East, Suite 3500 Los Angeles, California 90067-3021 Telephone: (310) 277-7200 Facsimile: (310) 201-5219 SEYFARTH SHAW LLP Robin E. Devaux (SBN 233444) Andrew Verriere (SBN 264674) 560 Mission Street, 31st Floor San Francisco, California 94105 Telephone: (415) 397-2823 Facsimile: (415) 397-8549 Attorneys For Defendant CONTINENTAL CASUALTY COMPANY 13 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 17 MICHAEL MUSA, an individual, Case No. 16-cv-03006-LB 18 Plaintiff, STIPULATED PROTECTIVE ORDER 19 v. 20 CONTINENTAL CASUALTY COMPANY, 21 Defendant. 22 23 24 25 Plaintiff MICHAEL MUSA and Defendant CONTINENTAL CASUALTY COMPANY (collectively, “the Parties”), subject to the approval of the Court, hereby stipulate and agree to entry of this Stipulated Protective Order. 26 27 28 STIPULATED PROTECTIVE ORDER 28540050v.1 1 1. PURPOSES AND LIMITATIONS Disclosure and discovery activity in this action are likely to involve production of confidential, 2 3 proprietary, or private information for which special protection from public disclosure and from use for 4 any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby 5 stipulate to and petition the court to enter the following Stipulated Protective Order. The parties 6 acknowledge that this Order does not confer blanket protections on all disclosures or responses to 7 discovery and that the protection it affords from public disclosure and use extends only to the limited 8 information or items that are entitled to confidential treatment under the applicable legal principles. The 9 parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 10 does not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets forth the 11 procedures that must be followed and the standards that will be applied when a party seeks permission 12 from the court to file material under seal. 13 2. 2.1 14 15 DEFINITIONS Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.2 16 “CONFIDENTIAL” Information or Items: information (regardless of how it is generated, 17 stored or maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure 18 26(c). 19 2.3 20 their support staff). 21 2.4 22 23 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 2.5 Disclosure or Discovery Material: all items or information, regardless of the medium or 24 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 discovery 26 in this matter. 27 28 2 STIPULATED PROTECTIVE ORDER 28540050v.1 1 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to the 2 litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant 3 in this action. 4 5 2.7 does not include Outside Counsel of Record or any other outside counsel. 6 7 2.8 10 2.9 party or are affiliated with a law firm which has appeared on behalf of that party. 2.10 Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, and Outside Counsel of Record (and their support staffs). 13 14 Outside Counsel of Record: attorneys who are not employees of a party to this action but are retained to represent or advise a party to this action and have appeared in this action on behalf of that 11 12 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 8 9 House Counsel: attorneys who are employees of a party to this action. House Counsel 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action. 15 2.12 Professional Vendors: persons or entities that provide litigation support services (e.g., 16 photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or 17 retrieving data in any form or medium) and their employees and subcontractors. 18 19 2.13 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 20 2.14 21 Party. 22 3. Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing 23 SCOPE The protections conferred by this Stipulation and Order cover not only Protected Material (as 24 defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, 25 excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or 26 presentations by Parties or their Counsel that might reveal Protected Material. However, the protections 27 conferred by this Stipulation and Order do not cover the following information: (a) any information that 28 is in the public domain at the time of disclosure to a Receiving Party or becomes part of the public 3 STIPULATED PROTECTIVE ORDER 28540050v.1 1 domain after its disclosure to a Receiving Party as a result of publication not involving a violation of this 2 Order, including becoming part of the public record through trial or otherwise; and (b) any information 3 known to the Receiving Party prior to the disclosure or obtained by the Receiving Party after the 4 disclosure from a source who obtained the information lawfully and under no obligation of 5 confidentiality to the Designating Party. Any use of Protected Material at trial shall be governed by a 6 separate agreement or order. 7 4. 8 9 DURATION Even after final disposition of this litigation, the confidentiality obligations imposed by this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order 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 and 12 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the time limits 13 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 limit 17 any such designation to specific material that qualifies under the appropriate standards. The Designating 18 Party must designate for protection only those parts of material, documents, items, or oral or written 19 communications that qualify — so that other portions of the material, documents, items, or 20 communications for which protection is not warranted are not swept unjustifiably within the ambit of 21 this Order. 22 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to 23 be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber 24 or slow down the case development process or to impose unnecessary expenses and burdens on other 25 parties) expose the Designating Party to sanctions. 26 If it comes to a Designating Party’s attention that information or items that it designated for 27 protection do not qualify for protection, that Designating Party must promptly notify all other Parties 28 that it is withdrawing the mistaken designation. 4 STIPULATED PROTECTIVE ORDER 28540050v.1 1 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see, 2 e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 3 Discovery Material that qualifies for protection under this Order must be clearly so designated before 4 the material is disclosed or produced. 5 Designation in conformity with this Order requires: 6 (a) for information in documentary form (e.g., paper or electronic documents, but excluding 7 transcripts of depositions or other pretrial or trial proceedings), that the Producing Party affix the legend 8 “CONFIDENTIAL” to each page that contains protected material. If only a portion or portions of the 9 material on a page qualifies for protection, the Producing Party also must clearly identify the protected 10 portion(s) (e.g., by making appropriate markings in the margins). 11 A Party or Non-Party that makes original documents or materials available for inspection need 12 not designate them for protection until after the inspecting Party has indicated which material it would 13 like copied and produced. During the inspection and before the designation, all of the material made 14 available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has identified 15 the documents it wants copied and produced, the Producing Party must determine which documents, or 16 portions thereof, qualify for protection under this Order. Then, before producing the specified 17 documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page that contains 18 Protected Material. If only a portion or portions of the material on a page qualifies for protection, the 19 Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate 20 markings in the margins). 21 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the 22 Designating Party identify on the record, before the close of the deposition, hearing, or other proceeding, 23 or in writing, no later than thirty (30) days after receipt of the deposition transcript by counsel for the 24 witness, 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 portion or 28 5 STIPULATED PROTECTIVE ORDER 28540050v.1 1 portions of the information or item warrant protection, the Producing Party, to the extent practicable, 2 shall identify the protected portion(s). 3 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate 4 qualified information or items does not, standing alone, waive the Designating Party’s right to secure 5 protection under this Order for such material. Upon timely correction of a designation, the Receiving 6 Party must make reasonable efforts to assure that the material is treated in accordance with the 7 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, or 12 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 designation 14 is disclosed. 15 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process by 16 providing written notice of each designation it is challenging and describing the basis for each challenge. 17 To avoid ambiguity as to whether a challenge has been made, the written notice must recite that the 18 challenge to confidentiality is being made in accordance with this specific paragraph of the Protective 19 Order. The parties shall attempt to resolve each challenge in good faith and must begin the process by 20 conferring directly (in voice to voice dialogue; other forms of communication are not sufficient) within 21 14 days of the date of service of notice. In conferring, the Challenging Party must explain the basis for 22 its belief that the confidentiality designation was not proper and must give the Designating Party an 23 opportunity to review the designated material, to reconsider the circumstances, and, if no change in 24 designation is offered, to explain the basis for the chosen designation. A Challenging Party may proceed 25 to the next stage of the challenge process only if it has engaged in this meet and confer process first or 26 establishes that the Designating Party is unwilling to participate in the meet and confer process in a 27 timely manner. 28 6 STIPULATED PROTECTIVE ORDER 28540050v.1 1 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court intervention, 2 the Designating Party shall file and serve a motion to retain confidentiality under Civil Local Rule 7 3 (and in compliance with Civil Local Rule 79-5, if applicable) within 21 days of the initial notice of 4 challenge or within 14 days of the parties agreeing that the meet and confer process will not resolve their 5 dispute, whichever is earlier. Each such motion must be accompanied by a competent declaration 6 affirming that the movant has complied with the meet and confer requirements imposed in the preceding 7 paragraph. Failure by the Designating Party to make such a motion including the required declaration 8 within 21 days (or 14 days, if applicable) shall automatically waive the confidentiality designation for 9 each challenged designation. In addition, the Challenging Party may file a motion challenging a 10 confidentiality designation at any time if there is good cause for doing so, including a challenge to the 11 designation of a deposition transcript or any portions thereof. Any motion brought pursuant to this 12 provision must be accompanied by a competent declaration affirming that the movant has complied with 13 the meet and confer requirements imposed by the preceding paragraph. 14 The burden of persuasion in any such challenge proceeding shall be on the Designating Party. 15 Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose unnecessary 16 expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the 17 Designating Party has waived the confidentiality designation by failing to file a motion to retain 18 confidentiality as described above, all parties shall continue to afford the material in question the level 19 of protection to which it is entitled under the Producing Party’s designation until the court rules on the 20 challenge. 21 7. 22 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 23 produced by another Party or by a Non-Party in connection with this case only for prosecuting, 24 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to the 25 categories of persons and under the conditions described in this Order. When the litigation has been 26 terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL 27 DISPOSITION). 28 7 STIPULATED PROTECTIVE ORDER 28540050v.1 1 2 3 Protected Material must be stored and maintained by a Receiving Party at a location and in a secure manner that ensures that access is limited to the persons authorized under this Order. 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the 4 court or permitted in writing by the Designating Party, a Receiving Party may disclose any information 5 or item designated “CONFIDENTIAL” only to: 6 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees of 7 said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this 8 litigation and who have signed the “Acknowledgment and Agreement to Be Bound” that is attached 9 hereto as Exhibit A; 10 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party 11 to whom disclosure is reasonably necessary for this litigation and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 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 Agreement to 15 Be Bound” (Exhibit A); 16 (d) the court and its personnel; 17 (e) court reporters and their staff, professional jury or trial consultants, mock jurors, and 18 Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have signed 19 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (f) during their depositions, witnesses in the action to whom disclosure is reasonably 21 necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 22 otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed deposition 23 testimony or exhibits to depositions that reveal Protected Material must be separately bound by the court 24 reporter and may not be disclosed to anyone except as permitted under this Stipulated Protective Order. 25 26 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information. 27 28 8 STIPULATED PROTECTIVE ORDER 28540050v.1 1 8. 2 3 If a Party is served with a subpoena or a court order issued in other litigation that compels disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party must: 4 5 (a) 8 (b) Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and (c) 13 14 15 16 17 cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 11 12 promptly notify in writing the party who caused the subpoena or order to issue in the other litigation that some or all of the material covered by the subpoena or order is subject to this 9 10 promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; 6 7 PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION If the Designating Party timely seeks a protective order, the Party served with the subpoena or court order shall not produce any information designated in this action as “CONFIDENTIAL” before a determination by the court from which the subpoena or order issued, unless the Party has obtained the Designating Party’s permission. The Designating Party shall bear the burden and expense of seeking protection in that court of its confidential material—and nothing in these provisions should be construed as authorizing or encouraging a Receiving Party in this action to disobey a lawful directive from another court. 18 19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 20 (a) The terms of this Order are applicable to information produced by a Non-Party in this 21 action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in connection 22 with this litigation is protected by the remedies and relief provided by this Order. Nothing in these 23 provisions should be construed as prohibiting a Non-Party from seeking additional protections. 24 (b) In the event that a Party is required, by a valid discovery request, to produce a Non- 25 Party’s confidential information in its possession, and the Party is subject to an agreement with the Non- 26 Party not to produce the Non-Party’s confidential information, then the Party shall: 1. 27 28 promptly notify in writing the Requesting Party and the Non-Party that some or all of the information requested is subject to a confidentiality agreement with a Non-Party; 9 STIPULATED PROTECTIVE ORDER 28540050v.1 1 2. promptly provide the Non-Party with a copy of the Stipulated Protective Order in 2 this litigation, the relevant discovery request(s), and a reasonably specific description of the information 3 requested; and 4 3. 5 (c) make the information requested available for inspection by the Non-Party. If the Non-Party fails to object or seek a protective order from this court within 14 days 6 of receiving the notice and accompanying information, the Receiving Party may produce the Non- 7 Party’s confidential information responsive to the discovery request. If the Non-Party timely seeks a 8 protective order, the Receiving Party shall not produce any information in its possession or control that 9 is subject to the confidentiality agreement with the Non-Party before a determination by the court. 10 Absent a court order to the contrary, the Non-Party shall bear the burden and expense of seeking 11 protection in this court of its Protected Material. 12 10. 13 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected Material 14 to any person or in any circumstance not authorized under this Stipulated Protective Order, the 15 Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized 16 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) 17 inform the person or persons to whom unauthorized disclosures were made of all the terms of this Order, 18 and (d) request such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 19 that is attached hereto as Exhibit A. 20 11. 21 MANAGEMENT OF ATTORNEY-CLIENT AND WORK PRODUCT PROTECTION The Parties agree that the production of communications, documents or information (“Privileged 22 Material”) protected by the attorney-client privilege, work product doctrine, or any other privilege or 23 protection from disclosure, whether inadvertent or otherwise, is not a waiver of the privilege or 24 protection from discovery in this case or in any other federal or state proceeding. 25 Upon written notification from the Producing Party to the Receiving Party identifying Privileged 26 Material, the receiving party shall not review the disclosed Privileged Material in any respect; shall, 27 within 10 days, return, delete, or destroy all copies of the disclosed Privileged Material (including any 28 and all work-product containing such Privileged Material); shall take reasonable steps to retrieve such 10 STIPULATED PROTECTIVE ORDER 28540050v.1 1 Privileged Material if the receiving party disclosed it before being notified; and shall make no further 2 use of such Privileged Material (or work product containing such Privileged Material). 3 If the Receiving Party receives documents, ESI, or other forms of information from the 4 Producing Party that, upon inspection or review, potentially appears, in any respect, to contain or 5 constitute Privileged Material, the Receiving Party shall immediately stop review of such information, 6 promptly return, delete, or destroy all copies of the Privileged Material and identify the Privileged 7 Material to the Producing Party. 8 9 A Party returning produced Privileged Material, however, may thereafter seek reproduction of any such documents pursuant to applicable law. 10 The Parties agree that this Section shall be interpreted to provide the maximum protection 11 allowed by Federal Rule of Evidence 502(d). 12 12. 13 14 15 MISCELLANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the court in the future. 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order no 16 Party waives any right it otherwise would have to object to disclosing or producing any information or 17 item on any ground not addressed in this Stipulated Protective Order. Similarly, no Party waives any 18 right to object on any ground to use in evidence of any of the material covered by this Protective Order. 19 12.3 Filing Protected Material. Without written permission from the Designating Party or a 20 court order secured after appropriate notice to all interested persons, a Party may not file in the public 21 record in this action any Protected Material. A Party that seeks to file under seal any Protected Material 22 must comply with Civil Local Rule 79-5 and General Order 62. Protected Material may only be filed 23 under seal pursuant to a court order authorizing the sealing of the specific Protected Material at issue. 24 Pursuant to Civil Local Rule 79-5 and General Order 62, a sealing order will issue only upon a request 25 establishing that the Protected Material at issue is privileged, protectable as a trade secret, or otherwise 26 entitled to protection under the law. If a Receiving Party’s request to file Protected Material under seal 27 pursuant to Civil Local Rule 79¬5(d) and General Order 62 is denied by the court, then the Receiving 28 11 STIPULATED PROTECTIVE ORDER 28540050v.1 1 Party may file the information in the public record pursuant to Civil Local Rule 79-5(e) and General 2 Order 62 unless otherwise instructed by the court. 3 13. FINAL DISPOSITION 4 Within 60 days after the final disposition of this action, as defined in paragraph 4, each 5 Receiving Party must return all Protected Material to the Producing Party or destroy such material. As 6 used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, summaries, 7 and any other format reproducing or capturing any of the Protected Material. Whether the Protected 8 Material is returned or destroyed, the Receiving Party must submit a written certification to the 9 Producing Party (and, if not the same person or entity, to the Designating Party) by the 60 day deadline 10 that (1) identifies (by category, where appropriate) all the Protected Material that was returned or 11 destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts, compilations, 12 summaries or any other format reproducing or capturing any of the Protected Material. Notwithstanding 13 this provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, 14 deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, 15 expert reports, attorney work product, and consultant and expert work product, even if such materials 16 contain Protected Material. Any such archival copies that contain or constitute Protected Material 17 remain subject to this Protective Order as set forth in Section 4 (DURATION). 18 19 20 21 22 23 24 25 26 27 28 12 STIPULATED PROTECTIVE ORDER 28540050v.1 1 DATED: September ___, 2016 Respectfully submitted, 2 LOUDERBACK LAW GROUP LAW OFFICES OF JOHN FITZPATRICK VANNUCCI 3 4 5 By: Charles M. Louderback John F. Vannucci Attorneys for Plaintiff MICHAEL MUSA 6 7 8 DATED: September 15, 2016 Respectfully submitted, 9 SEYFARTH SHAW LLP 10 11 By: Robin E. Devaux Camille A. Olson Richard B. Lapp Andrew Verriere Robin E. Devaux 12 13 14 Attorneys for Defendant CONTINENTAL CASUALTY COMPANY 15 16 17 PURSUANT TO STIPULATION, IT IS SO ORDERED. 18 19 20 DATED: September ___, 2016 Hon. Laurel Beeler United States Magistrate Judge 20 21 22 23 24 25 26 27 28 13 STIPULATED PROTECTIVE ORDER 28540050v.1 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ___________________________________, declare under penalty of perjury that I have read 4 in its entirety and understand the Stipulated Protective Order that was issued by the United States 5 District Court for the Northern District of California on ____________________________ in the case of 6 Michael Musa v. Continental Casualty Company, Case No. 3:16-cv-03006-LB. I agree to comply with 7 and to be bound by all the terms of this Stipulated Protective Order and I understand and acknowledge 8 that failure to so comply could expose me to sanctions and punishment in the nature of contempt. I 9 solemnly promise that I will not disclose in any manner any information or item that is subject to this 10 Stipulated Protective Order to any person or entity except in strict compliance with the provisions of this 11 Order. 12 I further agree to submit to the jurisdiction of the United States District Court for the Northern 13 District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if 14 such 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 17 number] as my California agent for service of process in connection with this action or any proceedings 18 related to enforcement of this Stipulated Protective Order. 19 Date: 20 City and State where sworn and signed: 21 Printed name: 22 Signature: 23 24 25 26 27 28 14 STIPULATED PROTECTIVE ORDER 28540050v.1

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