Wainwright v. Bluestem Brands, Inc.

Filing 26

STIPULATION AND ORDER re 25 STIPULATION WITH PROPOSED ORDER Stipulated Protective Order filed by Bluestem Brands, Inc. Signed by Judge Jon S. Tigar on December 1, 2017. (wsn, COURT STAFF) (Filed on 12/1/2017)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 DOLL AMIR & ELEY LLP HUNTER R. ELEY (SBN 224321) heley@dollamir.com CHELSEA L. DIAZ (SBN 271859) cdiaz@dollamir.com 1888 Century Park East, Suite 1850 Los Angeles, California 90067 Tel: 310.557.9100 Fax: 310.557.9101 Attorneys for Defendant BLUESTEM BRANDS, INC. Amy Lynn Bennecoff Ginsburg (275805) Rachel Rebecca Stevens (261360) Kimmel & Silverman, P.C. 30 East Butler Pike Ambler, PA 19002 Telephone: (215) 540-8888 Facsimile: (215) 540-8817 aginsburg@creditlaw.com Attorneys for Plaintiff SUISUN WAINWRIGHT 16 17 UNITED STATES DISTRICT COURT 18 FOR THE NORTHERN DISTRICT OF CALIFORNIA 19 20 SUISUN WAINWRIGHT, Plaintiff, 21 22 23 24 Case No.: 3:17-cv-03041-JST Assigned to the Honorable Jon S. Tigar STIPULATED PROTECTIVE ORDER vs. BLUESTEM BRANDS D/B/A FINGERHUT, Complaint Filed: Trial Date: Defendant. 25 26 27 28 1 STIPULATED PROTECTIVE ORDER May 26, 2017 TBD 1 1. PURPOSES AND LIMITATIONS Disclosure and discovery activity in this action are likely to involve production 2 3 of confidential, proprietary, or private information for which special protection from 4 public disclosure and from use for any purpose other than prosecuting this litigation 5 may be warranted. Accordingly, plaintiff Suisun Wainwright and Defendant 6 Bluestem Brands, Inc. (collectively, the “parties”) hereby stipulate to and petition the 7 court to enter the following Stipulated Protective Order. The parties acknowledge 8 that this Order does not confer blanket protections on all disclosures or responses to 9 discovery and that the protection it affords from public disclosure and use extends 10 only to the limited information or items that are entitled to confidential treatment 11 under the applicable legal principles. The parties further acknowledge, as set forth in 12 Section 12.3, below, that this Stipulated Protective Order does not entitle them to file 13 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures 14 that must be followed and the standards that will be applied when a party seeks 15 permission from the court to file material under seal. 16 2. 17 18 19 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 20 how it is generated, stored or maintained) or tangible things that qualify for protection 21 under Federal Rule of Civil Procedure 26(c). 22 23 24 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 25 items that it produces in disclosures or in responses to discovery as 26 “CONFIDENTIAL.” 27 28 2.5 Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, 2 STIPULATED PROTECTIVE ORDER 1 among other things, testimony, transcripts, and tangible things) that are produced or 2 generated in disclosures or responses to discovery in this matter. 2.6 3 Expert: a person with specialized knowledge or experience in a matter 4 pertinent to the litigation who has been retained by a Party or its counsel to serve as 5 an expert witness or as a consultant in this action. 2.7 6 House Counsel: attorneys who are employees of a party to this action. 7 House Counsel does not include Outside Counsel of Record or any other outside 8 counsel. 2.8 9 10 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.9 11 Outside Counsel of Record: attorneys who are not employees of a party 12 to this action but are retained to represent or advise a party to this action and have 13 appeared in this action on behalf of that party or are affiliated with a law firm which 14 has appeared on behalf of that party. 2.10 Party: any party to this action, including all of its officers, directors, 15 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 2.11 Producing Party: a Party or Non-Party that produces Disclosure or 18 19 Discovery Material in this action. 2.12 Professional Vendors: persons or entities that provide litigation support 20 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) 23 and their employees and subcontractors. 2.13 Protected Material: any Disclosure or Discovery Material that is 24 25 designated as “CONFIDENTIAL.” 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material 26 27 from a Producing Party. 28 /// 3 STIPULATED PROTECTIVE ORDER 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. 7 However, the protections conferred by this Stipulation and Order do not cover the 8 following information: (a) any information that is in the public domain at the time of 9 disclosure to a Receiving Party or becomes part of the public domain after its 10 disclosure to a Receiving Party as a result of publication not involving a violation of 11 this Order, including becoming part of the public record through trial or otherwise; 12 and (b) any information known to the Receiving Party prior to the disclosure or 13 obtained by the Receiving Party after the disclosure from a source who obtained the 14 information lawfully and under no obligation of confidentiality to the Designating 15 Party. Any use of Protected Material at trial shall be governed by a separate 16 agreement or order. 17 4. DURATION Even after final disposition of this litigation, the confidentiality obligations 18 19 imposed by this Order shall remain in effect until a Designating Party agrees 20 otherwise in writing or a court order otherwise directs. Final disposition shall be 21 deemed to be the later of (1) dismissal of all claims and defenses in this action, with 22 or without prejudice; and (2) final judgment herein after the completion and 23 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 24 including the time limits for filing any motions or applications for extension of time 25 pursuant to applicable law. 26 5. 27 28 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-Party that designates information or items for protection under this 4 STIPULATED PROTECTIVE ORDER 1 Order must take care to limit any such designation to specific material that qualifies 2 under the appropriate standards. The Designating Party must designate for protection 3 only those parts of material, documents, items, or oral or written communications that 4 qualify – so that other portions of the material, documents, items, or communications 5 for which protection is not warranted are not swept unjustifiably within the ambit of 6 this Order. 7 Mass, indiscriminate, or routinized designations are prohibited. Designations 8 that are shown to be clearly unjustified or that have been made for an improper 9 purpose (e.g., to unnecessarily encumber or retard the case development process or to 10 impose unnecessary expenses and burdens on other parties) expose the Designating 11 Party to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the mistaken designation. 15 5.2 Manner and Timing of Designations. Except as otherwise provided in 16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 18 under this Order must be clearly so designated before the material is disclosed or 19 produced. 20 21 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 22 documents, but excluding transcripts of depositions or other pretrial or trial 23 proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to 24 each page that contains protected material. If only a portion or portions of the 25 material on a page qualifies for protection, the Producing Party also must 26 clearly identify the protected portion(s) (e.g., by making appropriate markings 27 in the margins). 28 A Party or Non-Party that makes original documents or materials 5 STIPULATED PROTECTIVE ORDER 1 available for inspection need not designate them for protection until after the 2 inspecting Party has indicated which material it would like copied and 3 produced. During the inspection and before the designation, all of the material 4 made available for inspection shall be deemed “CONFIDENTIAL.” After the 5 inspecting Party has identified the documents it wants copied and produced, the 6 Producing Party must determine which documents, or portions thereof, qualify 7 for protection under this Order. Then, before producing the specified 8 documents, the Producing Party must affix the “CONFIDENTIAL” legend to 9 each page that contains Protected Material. If only a portion or portions of the 10 material on a page qualifies for protection, the Producing Party also must 11 clearly identify the protected portion(s) (e.g., by making appropriate markings 12 in the margins). (b) for testimony given in deposition or in other pretrial or trial 13 14 proceedings, that the Designating Party identify on the record, before the close 15 of the deposition, hearing, or other proceeding, all protected testimony. (c) for information produced in some form other than documentary and 16 17 for any other tangible items, that the Producing Party affix in a prominent place 18 on the exterior of the container or containers in which the information or item 19 is stored the legend “CONFIDENTIAL.” If only a portion or portions of the 20 information or item warrant protection, the Producing Party, to the extent 21 practicable, shall identify the protected portion(s). 22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 23 failure to designate qualified information or items does not, standing alone, waive the 24 Designating Party’s right to secure protection under this Order for such material. 25 Upon timely correction of a designation, the Receiving Party must make reasonable 26 efforts to assure that the material is treated in accordance with the provisions of this 27 Order. 28 /// 6 STIPULATED PROTECTIVE ORDER 1 2 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time. Unless a prompt challenge to a 4 Designating Party’s confidentiality designation is necessary to avoid foreseeable, 5 substantial unfairness, unnecessary economic burdens, or a significant disruption or 6 delay of the litigation, a Party does not waive its right to challenge a confidentiality 7 designation by electing not to mount a challenge promptly after the original 8 designation is disclosed. 9 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 10 resolution process by providing written notice of each designation it is challenging 11 and describing the basis for each challenge. To avoid ambiguity as to whether a 12 challenge has been made, the written notice must recite that the challenge to 13 confidentiality is being made in accordance with this specific paragraph of the 14 Protective Order. The parties shall attempt to resolve each challenge in good faith 15 and must begin the process by conferring directly (in voice to voice dialogue; other 16 forms of communication are not sufficient) within 14 days of the date of service of 17 notice. In conferring, the Challenging Party must explain the basis for its belief that 18 the confidentiality designation was not proper and must give the Designating Party an 19 opportunity to review the designated material, to reconsider the circumstances, and, if 20 no change in designation is offered, to explain the basis for the chosen designation. 21 A Challenging Party may proceed to the next stage of the challenge process only if it 22 has engaged in this meet and confer process first or establishes that the Designating 23 Party is unwilling to participate in the meet and confer process in a timely manner. 24 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without 25 court intervention, the Designating Party shall file and serve a motion to retain 26 confidentiality under Civil Local Rule 7 (and in compliance with Civil Local Rule 27 79-5, if applicable) within 21 days of the initial notice of challenge or within 14 days 28 of the parties agreeing that the meet and confer process will not resolve their dispute, 7 STIPULATED PROTECTIVE ORDER 1 whichever is earlier. Each such motion must be accompanied by a competent 2 declaration affirming that the movant has complied with the meet and confer 3 requirements imposed in the preceding paragraph. Failure by the Designating Party to 4 make such a motion including the required declaration within 21 days (or 14 days, if 5 applicable) shall automatically waive the confidentiality designation for each 6 challenged designation. In addition, the Challenging Party may file a motion 7 challenging a confidentiality designation at any time if there is good cause for doing 8 so, including a challenge to the designation of a deposition transcript or any portions 9 thereof. Any motion brought pursuant to this provision must be accompanied by a 10 competent declaration affirming that the movant has complied with the meet and 11 confer requirements imposed by the preceding paragraph. The burden of persuasion 12 in any such challenge proceeding shall be on the Designating Party. Frivolous 13 challenges, and those made for an improper purpose (e.g., to harass or impose 14 unnecessary expenses and burdens on other parties) may expose the Challenging 15 Party to sanctions. Unless the Designating Party has waived the confidentiality 16 designation by failing to file a motion to retain confidentiality as described above, all 17 parties shall continue to afford the material in question the level of protection to 18 which it is entitled under the Producing Party’s designation until the court rules on 19 the challenge. 20 7. 21 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 22 disclosed or produced by another Party or by a Non-Party in connection with this case 23 only for prosecuting, defending, or attempting to settle this litigation. Such Protected 24 Material may be disclosed only to the categories of persons and under the conditions 25 described in this Order. When the litigation has been terminated, a Receiving Party 26 must comply with the provisions of section 13 below (FINAL DISPOSITION). 27 28 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 8 STIPULATED PROTECTIVE ORDER 1 2 authorized under this Order. 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 3 otherwise ordered by the court or permitted in writing by the Designating Party, a 4 Receiving Party may disclose any information or item designated 5 “CONFIDENTIAL” only to: 6 (a) the Receiving Party’s Outside Counsel of Record in this action, as 7 well as employees of said Outside Counsel of Record to whom it is reasonably 8 necessary to disclose the information for this litigation and who have signed 9 the “Acknowledgment and Agreement to Be Bound” that is attached hereto as 10 11 Exhibit A; (b) the officers, directors, and employees (including House Counsel) of 12 the Receiving Party to whom disclosure is reasonably necessary for this 13 litigation and who have signed the “Acknowledgment and Agreement to Be 14 Bound” (Exhibit A); 15 (c) Experts (as defined in this Order) of the Receiving Party to whom 16 disclosure is reasonably necessary for this litigation and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d) the court and its personnel; 19 (e) court reporters and their staff, professional jury or trial consultants, 20 mock jurors, and Professional Vendors to whom disclosure is reasonably 21 necessary for this litigation and who have signed the “Acknowledgment and 22 Agreement to Be Bound” (Exhibit A); 23 (f) during their depositions, witnesses in the action to whom disclosure 24 is reasonably necessary and who have signed the “Acknowledgment and 25 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the 26 Designating Party or ordered by the court. Pages of transcribed deposition 27 testimony or exhibits to depositions that reveal Protected Material must be 28 separately bound by the court reporter and may not be disclosed to anyone 9 STIPULATED PROTECTIVE ORDER except as permitted under this Stipulated Protective Order. 1 (g) the author or recipient of a document containing the information or a 2 custodian or other person who otherwise possessed or knew the information. 3 4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 5 IN OTHER LITIGATION 6 If a Party is served with a subpoena or a court order issued in other litigation 7 that compels disclosure of any information or items designated in this action as 8 “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification 9 shall include a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the subpoena or 11 12 order to issue in the other litigation that some or all of the material covered by 13 the subpoena or order is subject to this Protective Order. Such notification 14 shall include a copy of this Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be 15 16 pursued by the Designating Party whose Protected Material may be affected. 17 If the Designating Party timely seeks a protective order, the Party served with 18 the subpoena or court order shall not produce any information designated in this 19 action as “CONFIDENTIAL” before a determination by the court from which the 20 subpoena or order issued, unless the Party has obtained the Designating Party’s 21 permission. The Designating Party shall bear the burden and expense of seeking 22 protection in that court of its confidential material – and nothing in these provisions 23 should be construed as authorizing or encouraging a Receiving Party in this action to 24 disobey a lawful directive from another court. 25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 26 PRODUCED IN THIS LITIGATION 27 The terms of this Order are applicable to information produced by a Non-Party 28 in this action and designated as “CONFIDENTIAL.” Such information produced by 10 STIPULATED PROTECTIVE ORDER 1 Non-Parties in connection with this litigation is protected by the remedies and relief 2 provided by this Order. Nothing in these provisions should be construed as 3 prohibiting a Non-Party from seeking additional protections. 4 In the event that a Party is required, by a valid discovery request, to produce a 5 Non-Party’s confidential information in its possession, and the Party is subject to an 6 agreement with the Non-Party not to produce the Non-Party’s confidential 7 information, then the Party shall: (1) promptly notify in writing the Requesting Party and the Non-Party 8 that some or all of the information requested is subject to a confidentiality 9 agreement with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated 11 12 Protective Order in this litigation, the relevant discovery request(s), and a 13 reasonably specific description of the information requested; and (3) make the information requested available for inspection by the Non- 14 15 Party. 16 If the Non-Party fails to object or seek a protective order from this court within 17 14 days of receiving the notice and accompanying information, the Receiving Party 18 may produce the Non-Party’s confidential information responsive to the discovery 19 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 20 not produce any information in its possession or control that is subject to the 21 confidentiality agreement with the Non-Party before a determination by the court. 22 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 23 of seeking protection in this court of its Protected Material. 24 10. 25 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 Protected Material to any person or in any circumstance not authorized under this 27 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 28 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 11 STIPULATED PROTECTIVE ORDER 1 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 2 persons to whom unauthorized disclosures were made of all the terms of this Order, 3 and (d) request such person or persons to execute the “Acknowledgment and 4 Agreement to Be Bound” that is attached hereto as Exhibit A. 5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 6 PROTECTED MATERIAL 7 When a Producing Party gives notice to Receiving Parties that certain 8 inadvertently produced material is subject to a claim of privilege or other protection, 9 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 10 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 11 may be established in an e-discovery order that provides for production without prior 12 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 13 parties reach an agreement on the effect of disclosure of a communication or 14 information covered by the attorney-client privilege or work product protection, the 15 parties may incorporate their agreement in the stipulated protective order submitted to 16 the court. 17 12. 18 19 20 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 21 Protective Order no Party waives any right it otherwise would have to object to 22 disclosing or producing any information or item on any ground not addressed in this 23 Stipulated Protective Order. Similarly, no Party waives any right to object on any 24 ground to use in evidence of any of the material covered by this Protective Order. 25 12.3 Filing Protected Material. Without written permission from the 26 Designating Party or a court order secured after appropriate notice to all interested 27 persons, a Party may not file in the public record in this action any Protected 28 Material. A Party that seeks to file under seal any Protected Material must comply 12 STIPULATED PROTECTIVE ORDER 1 with Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant 2 to a court order authorizing the sealing of the specific Protected Material at issue. 3 Pursuant to Civil Local Rule 79-5, a sealing order will issue only upon a request 4 establishing that the Protected Material at issue is privileged, protectable as a trade 5 secret, or otherwise entitled to protection under the law. If a Receiving Party's 6 request to file Protected Material under seal pursuant to Civil Local Rule 79-5(d) is 7 denied by the court, then the Receiving Party may file the information in the public 8 record pursuant to Civil Local Rule 79-5(e) unless otherwise instructed by the court. 9 13. FINAL DISPOSITION Within 60 days after the final disposition of this action, as defined in paragraph 10 11 4, each Receiving Party must return all Protected Material to the Producing Party or 12 destroy such material. As used in this subdivision, “all Protected Material” includes 13 all copies, abstracts, compilations, summaries, and any other format reproducing or 14 capturing any of the Protected Material. Whether the Protected Material is returned 15 or destroyed, the Receiving Party must submit a written certification to the Producing 16 Party (and, if not the same person or entity, to the Designating Party) by the 60 day 17 deadline that (1) identifies (by category, where appropriate) all the Protected Material 18 that was returned or destroyed and (2) affirms that the Receiving Party has not 19 retained any copies, abstracts, compilations, summaries or any other format 20 reproducing or capturing any of the Protected Material. Notwithstanding this 21 provision, Counsel are entitled to retain an archival copy of all pleadings, motion 22 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 23 deposition and trial exhibits, expert reports, attorney work product, and consultant 24 and expert work product, even if such materials contain Protected Material. Any 25 such archival copies that contain or constitute Protected Material remain subject to 26 this Protective Order as set forth in Section 4 (DURATION). 27 /// 28 /// 13 STIPULATED PROTECTIVE ORDER 1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 DATED: December 1, 2017 DOLL AMIR & ELEY LLP By: /s/ Chelsea L. Diaz . Chelsea L. Diaz Attorneys for Defendant BLUESTEM BRANDS, INC. 4 5 6 7 8 DATED: December 1, 2017 KIMMEL & SILVERMAN, P.C. By: /s/ Rachel Rebecca Stevens Rachel Rebecca Stevens Attorneys for Plaintiff SUISUN WAINWRIGHT 9 10 11 . 12 13 14 15 16 PURSUANT TO STIPULATION, IT IS SO ORDERED. December 1, 2017 DATED: ____________ ______________________________________ THE HONORABLE JON S. TIGAR UNITED STATES DISTRICT COURT JUDGE 17 18 19 20 21 22 23 24 25 26 27 28 14 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 ________________ [print or type full address], declare under penalty of perjury that I 5 have read in its entirety and understand the Stipulated Protective Order that was 6 issued by the United States District Court for the Northern District of California on 7 November __, 2017 in the case of Suisun Wainwright v. Bluestem Brands, Inc., case 8 number 3:17-cv-03041-JST. I agree to comply with and to be bound by all the terms 9 of this Stipulated Protective Order and I understand and acknowledge that failure to 10 so comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that 12 is subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Northern District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 Printed name: _______________________________ 26 Signature: __________________________________ 27 28 15 STIPULATED PROTECTIVE ORDER

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