Local Search Association v. City & County of San Francisco et al

Filing 102

STIPULATION AND PROTECTIVE ORDER re 99 Stipulation, filed by City & County of San Francisco, Local Search Association, Board of Supervisors of the City & County of San Francisco, Edwin M. Lee. Signed by Magistrate Judge Donna M. Ryu on 10/27/11. (ig, COURT STAFF) (Filed on 10/27/2011)

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1 2 3 4 5 6 DENNIS J. HERRERA, State Bar #139669 City Attorney DANNY CHOU, State Bar #180240 Chief of Complex and Special Litigation CHRISTINE VAN AKEN, State Bar #241755 FRANCESCA GESSNER, State Bar #247553 Deputy City Attorneys 1390 Market Street, 7th Floor San Francisco, California 94102 Telephone: (415) 554-3875 Facsimile: (415) 554-3985 E-Mail: christine.van.aken@sfgov.org 7 8 Attorneys for Defendants 9 10 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 LOCAL SEARCH ASSOCIATION, Case No. CV-11-2776 SBA (DMR) 14 Plaintiff, STIPULATION AND PROTECTIVE ORDER 15 vs. Date Action Filed Trial Date: 16 17 18 19 June 7, 2011 Not set CITY AND COUNTY OF SAN FRANCISCO; BOARD OF SUPERVISORS OF THE CITY AND COUNTY OF SAN FRANCISCO; and EDWIN M. LEE, in his official capacity as MAYOR of the City and County of San Francisco, Defendants. 20 21 Pursuant to Federal Rule of Civil Procedure 26(c), the parties have met and conferred and 22 agree that the discovery of CONFIDENTIAL INFORMATION in this matter shall be made pursuant 23 to the terms of this PROTECTIVE ORDER. 24 THEREFORE, plaintiff Local Search Association (“LSA”) and Defendants the City and 25 County of San Francisco, the Board of Supervisors of the City and County of San Francisco, and San 26 Francisco Mayor Edwin M. Lee (collectively, “the City”) stipulate, though their attorneys of record, to 27 the entry of an order as follows: 28 STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 1 n:\cxlit\li2011\111349\00708359.doc 1 1. PURPOSE AND LIMITATIONS 1.1 2 Disclosure and discovery activity in this action are likely to involve production of 3 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, the parties hereby stipulate to and petition the court to 6 enter the following Stipulated Protective Order. 1.2 7 As reflected in the September 13, 2011 agreement set forth in the parties’ Joint Report 8 Pursuant to Fed. R. Civ. P. 26(f) (see Dkt. No. 61) (the “Member Documents 9 Agreement”), Non-Party LSA members AT&T Advertising Solutions (“AT&T”) and 10 AGI Publishing, Inc., d/b/a Valley Yellow Pages (“AGI”) have consented to make 11 certain documents available to the City through Counsel of Record for LSA in response 12 to requests for production served on LSA pursuant to Fed. R. Civ. P. 34. Nothing in 13 this Stipulated Protective Order shall be construed contrary to or as modifying the terms 14 of the Member Documents Agreement. 1.3 15 The parties acknowledge that this Order does not confer blanket protections on all 16 disclosures or responses to discovery and that the protection it affords from public 17 disclosure and use extends only to the limited information or items that are entitled to 18 confidential treatment under the applicable legal principles. The parties further 19 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 20 does not entitle them to file confidential information under seal; Civil Local Rule 79-5 21 sets forth the procedures that must be followed and the standards that will be applied 22 when a party seeks permission from the court to file material under seal. 23 24 2. DEFINITIONS 2.1 or items under this Order. 25 26 Challenging Party: a Party or Non-Party that challenges the designation of information 2.2 Confidential Information or Items: information (regardless of how it is generated, 27 stored or maintained) or tangible things that a Designating Party has in good faith 28 designated as “CONFIDENTIAL,” in addition to all confidential business information, STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 2 n:\cxlit\li2011\111349\00708359.doc 1 trade secrets, or other documents or things qualifying for protection under Federal Rule 2 of Civil Procedure 26(c). 3 2.3 Counsel (without qualifier): Counsel of Record and their support staff. 4 2.4 Designating Party: produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 5 6 a Party or Non-Party that designates information or items that it 2.5 Disclosure or Discovery Material: all items or information, regardless of the medium 7 or manner in which it is generated, stored, or maintained (including, among other 8 things, testimony, transcripts, and tangible things), that are produced or generated in 9 disclosures or responses to discovery in this matter. 10 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to the 11 litigation who has been retained by a Party or its counsel to serve as an expert witness 12 or as a consultant in this action or who is employed by a Party or its counsel and is 13 providing expert services in this action. 14 2.7 Counsel” does not include Counsel of Record or any other outside counsel. 15 16 2.8 2.9 2.10 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action. 23 24 Party: any party to this action, including its officers, directors, employees, consultants, retained experts, and Counsel of Record (and their support staffs). 21 22 Counsel of Record: attorneys at Mayer Brown LLP or the Office of the San Francisco City Attorney. 19 20 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action, including but not limited to AT&T and AGI. 17 18 House Counsel: attorneys who are employees of LSA, AT&T, or AGI. “House 2.12 Professional Vendors: persons or entities that provide litigation support services (e.g., 25 photocopying, videotaping, translating, preparing exhibits or demonstrations, and 26 organizing, storing, or retrieving data in any form or medium) and their employees and 27 subcontractors. 28 STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 3 n:\cxlit\li2011\111349\00708359.doc 2.13 1 “CONFIDENTIAL.” 2 2.14 3 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party. 4 5 Protected Material: any Disclosure or Discovery Material that is designated as 3. SCOPE The protections conferred by this Stipulation and Order cover not only Protected Material (as 6 7 defined above), but also (1) any information copied or extracted from Protected Material; (2) all 8 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 9 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 10 However, the protections conferred by this Stipulation and Order do not cover the following 11 information: (a) any information that is in the public domain at the time of disclosure to a Receiving 12 Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of 13 publication not involving a violation of this Order, including becoming part of the public record 14 through trial or otherwise; and (b) any information known to the Receiving Party prior to the 15 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 16 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of 17 Protected Material at trial shall be governed by a separate agreement or order. 18 4. DURATION Even after final disposition of this litigation, the confidentiality obligations imposed by this 19 20 Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order 21 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and 22 defenses in this action, with or without prejudice; and (2) final judgment herein after the completion 23 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the 24 time limits for filing any motions or applications for extension of time pursuant to applicable law. 25 5. 26 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or 27 Non-Party that designates information or items for protection under this Order must 28 take care to limit any such designation to material that qualifies under the appropriate STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 4 n:\cxlit\li2011\111349\00708359.doc 1 standards. Designations that are shown to be clearly unjustified or that have been made 2 for an improper purpose (e.g., to unnecessarily encumber or retard the case 3 development process or to impose unnecessary expenses and burdens on other parties) 4 expose the Designating Party to sanctions. If it comes to a Designating Party’s 5 attention that information or items that it designated for protection do not qualify for 6 protection, that Designating Party must promptly notify all other Parties that it is 7 withdrawing the mistaken designation. 8 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see, 9 e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, 10 Disclosure or Discovery Material that qualifies for protection under this Order must be 11 clearly so designated before the material is disclosed or produced. Designation in 12 conformity with this Order requires: 13 (a) for information in documentary form (e.g., paper or electronic documents, but 14 excluding transcripts of depositions or other pretrial or trial proceedings), that 15 the Producing Party affix the legend “CONFIDENTIAL” to each page that 16 contains protected material. A Party or Non-Party that makes original 17 documents or materials available for inspection need not designate them for 18 protection until after the inspecting Party has indicated which material it would 19 like copied and produced. During the inspection and before the designation, all 20 of the material made available for inspection shall be deemed 21 “CONFIDENTIAL.” After the inspecting Party has identified the documents it 22 wants copied and produced, the Producing Party must determine which 23 documents, or portions thereof, qualify for protection under this Order. Then, 24 before producing the specified documents, the Producing Party must affix the 25 “CONFIDENTIAL” legend to each page that contains Protected Material. 26 (b) for testimony given in deposition or in other pretrial or trial proceedings, that 27 the Designating Party identify on the record, before the close of the deposition, 28 hearing, or other proceeding, all protected testimony. STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 5 n:\cxlit\li2011\111349\00708359.doc (c) 1 for information produced in some form other than documentary and for any 2 other tangible items, that the Producing Party affix in a prominent place on the 3 exterior of the container or containers in which the information or item is stored 4 the legend “CONFIDENTIAL.” 5.3 5 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 6 designate qualified information or items does not, standing alone, waive the 7 Designating Party’s right to secure protection under this Order for such material. In the 8 event that any Confidential Information or Items is inadvertently not so designated by 9 the Producing Party, any Party who notices the oversight shall promptly make it known 10 to the other Parties so that the Producing Party may correct the designation. Upon 11 timely correction of a designation, the Receiving Party must make reasonable efforts to 12 assure that the material is treated in accordance with the provisions of this Order. 13 14 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 15 confidentiality at any time. Unless a prompt challenge to a Designating Party’s 16 confidentiality designation is necessary to avoid foreseeable, substantial unfairness, 17 unnecessary economic burdens, or a significant disruption or delay of the litigation, a 18 Party does not waive its right to challenge a confidentiality designation by electing not 19 to mount a challenge promptly after the original designation is disclosed. 20 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process 21 by providing written notice of each designation it is challenging and describing the 22 basis for each challenge. To avoid ambiguity as to whether a challenge has been made, 23 the written notice must recite that the challenge to confidentiality is being made in 24 accordance with this specific paragraph of the Protective Order. The parties shall 25 attempt to resolve each challenge in good faith and must begin the process by 26 conferring directly (in voice to voice dialogue; other forms of communication are not 27 sufficient) within 14 days of the date of service of notice. In conferring, the 28 Challenging Party must explain the basis for its belief that the confidentiality STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 6 n:\cxlit\li2011\111349\00708359.doc 1 designation was not proper and must give the Designating Party an opportunity to 2 review the designated material, to reconsider the circumstances, and, if no change in 3 designation is offered, to explain the basis for the chosen designation. A Challenging 4 Party may proceed to the next stage of the challenge process only if it has engaged in 5 this meet and confer process first or establishes that the Designating Party is unwilling 6 to participate in the meet and confer process in a timely manner. 6.3 7 Judicial Intervention. If the Parties cannot resolve a challenge without court 8 intervention, any Party may seek judicial intervention by following the procedures for 9 resolution of discovery disputes set forth in the Notice of Reference and Order re 10 Discovery Procedures, ECF Document No. 69, issued by Magistrate Judge Donna M. 11 Ryu on October 18, 2011. Any joint letter regarding discovery disputes, or formal 12 briefing regarding discovery disputes, must include an attestation that the Party seeking 13 judicial intervention has complied with the meet and confer requirements imposed in 14 the preceding paragraph. Frivolous challenges, and those made for an improper 15 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) 16 may expose the Challenging Party to sanctions. The parties agree that the prevailing 17 party in a joint letter or motion seeking to remove or retain a CONFIDENTIAL 18 designation shall waive any entitlement to monetary sanctions, including attorney’s 19 fees, unless the Designating Party clearly shows that the challenge was made for an 20 improper purpose (e.g., to harass or impose unnecessary expenses or burdens on other 21 parties). 22 23 7. 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 25 prosecuting, defending, or attempting to settle this litigation. Such Protected Material 26 may be disclosed only to the categories of persons and under the conditions described 27 in this Order. Upon final disposition of this action (see Section 4, above), a Receiving 28 Party must comply with the provisions of section 13, below. Protected Material must STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 7 n:\cxlit\li2011\111349\00708359.doc 1 be stored and maintained by a Receiving Party at a location and in a secure manner that 2 ensures that access is limited to the persons authorized under this Order. 3 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 5 Confidential Information or Items only to: 6 (a) the Receiving Party’s Counsel of Record in this action, as well as 7 employees of said Counsel of Record to whom it is reasonably necessary 8 to disclose the information for this litigation; 9 (b) Experts (as defined in this Order) of the Receiving Party to whom 10 disclosure is reasonably necessary for this litigation and who have 11 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 (c) House Counsel to whom disclosure is reasonably necessary for this 13 litigation and who have signed the “Acknowledgment and Agreement to 14 Be Bound” (Exhibit A); 15 (d) the Court and its personnel; 16 (e) court reporters and their staff, professional jury or trial consultants, 17 mock jurors, and Professional Vendors to whom disclosure is reasonably 18 necessary for this litigation and who have signed the “Acknowledgment 19 and Agreement to Be Bound” (Exhibit A); 20 (f) during their depositions, witnesses in the action to whom disclosure is 21 reasonably necessary and who have signed the “Acknowledgment and 22 Agreement to Be Bound” (Exhibit A), with the exception that absent an 23 order of this Court, no information or items designated 24 CONFIDENTIAL by a Non-Party member of LSA may be disclosed to 25 any officer, director, or employee of any other Non-Party member of 26 LSA, under the presumption that any such disclosure is not reasonably 27 necessary to the disposition of this action. Pages of transcribed 28 deposition testimony or exhibits to depositions that reveal Protected STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 8 n:\cxlit\li2011\111349\00708359.doc 1 Material must be separately bound by the court reporter and may not be 2 disclosed to anyone except as permitted under this Stipulated Protective 3 Order. (g) 4 the author or recipient of a document containing the information, or a 5 custodian or other person who otherwise possessed or knew the 6 Confidential Information or Item prior to the commencement of this 7 lawsuit. 8 A Receiving Party may not provide Confidential Information or Items to the officers, 9 officials, directors, representatives, or employees of any Party (excluding House 10 Counsel) absent the written agreement of Counsel for the Producing Party or an Order 11 of this Court. However, for purposes of apprising such officers, officials, directors, 12 representatives, or employees of the status of this litigation, the Receiving Party may 13 disclose to such persons the general nature of the Confidential Information or Items 14 without disclosing its content or other details of the Confidential Information or Items. 15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 16 LITIGATION 17 If a Receiving Party is served with a subpoena or a court order issued in other litigation that 18 compels disclosure of any information or items designated in this action as “CONFIDENTIAL,” that 19 Receiving Party must: 20 (i) of the subpoena or court order; 21 22 promptly notify the Designating Party in writing. Such notification shall include a copy (ii) promptly notify in writing the party who caused the subpoena or order to issue in the 23 other litigation that some or all of the material covered by the subpoena or order is 24 subject to this Protective Order. Such notification shall include a copy of this 25 Stipulated Protective Order; and 26 27 (iii) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 28 STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 9 n:\cxlit\li2011\111349\00708359.doc 1 If the Designating Party timely seeks a protective order, the Party served with the subpoena or court 2 order shall not produce any information designated in this action as “CONFIDENTIAL” before a 3 determination by the court from which the subpoena or order issued, unless the Party has obtained the 4 Designating Party’s permission. The Designating Party shall bear the burden and expense of seeking 5 protection in that court of its confidential material, and nothing in these provisions should be construed 6 as authorizing or encouraging a Receiving Party in this action to disobey a lawful directive from 7 another court. 8 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 9 The terms of this Order are applicable to information produced by a Non-Party in this action 10 11 and designated as “CONFIDENTIAL.” Any party serving a subpoena on any Non-Party shall 12 concurrently deliver a copy of this Stipulated Protective Order, and such information produced by 13 Non-Parties in connection with this litigation is protected by the remedies and relief provided by this 14 Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking 15 additional protections. 16 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 17 18 Material to any person or in any circumstance not authorized under this Stipulated Protective Order, 19 the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized 20 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) 21 inform the person or persons to whom unauthorized disclosures were made of all the terms of this 22 Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to Be 23 Bound” that is attached hereto as Exhibit A. 24 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 25 MATERIAL 26 When a Producing Party gives notice to Receiving Parties that certain inadvertently produced 27 material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties 28 are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 10 n:\cxlit\li2011\111349\00708359.doc 1 modify whatever procedure may be established in any e-discovery order that provides for production 2 without prior privilege review. Pursuant to Federal Rules of Evidence 502(d) and (e), insofar as the 3 parties reach an agreement on the effect of disclosure of a communication or information covered by 4 the attorney-client privilege or work product protection, the parties may incorporate their agreement in 5 any further, appropriate stipulated protective order submitted to the court. 6 12. MISCELLANEOUS 12.1 7 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the court in the future. 8 12.2 9 Right to Assert Other Objections. By stipulating to the entry of this Protective Order, 10 no Party waives any right it otherwise would have to object to disclosing or producing 11 any information or item on any ground not addressed in this Stipulated Protective 12 Order. Similarly, no Party waives any right to object on any ground to the use in 13 evidence of any of the material covered by this Protective Order. 12.3 14 Filing Protected Material. Without written permission from the Designating Party or a 15 court order secured after appropriate notice to all interested persons, a Party may not 16 file in the public record in this action any Protected Material. Absent stipulation or 17 court order, a Receiving Party that seeks to file under seal any Protected Material must 18 comply with Civil Local Rule 79-5(d), and a Designating Party that seeks to file under 19 seal any Protected Material must comply with Civil Local Rule 79-5(b)-(c). Protected 20 Material may only be filed under seal pursuant to a court order authorizing the sealing 21 of the specific Protected Material at issue. 22 13. FINAL DISPOSITION 23 Within 30 days after the final disposition of this action, as defined in paragraph 4, each 24 Receiving Party must return all Protected Material to the Producing Party or destroy such material. As 25 used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 26 summaries, and any other format reproducing or capturing any of the Protected Material. Whether the 27 Protected Material is returned or destroyed, the Receiving Party must submit a written certification to 28 the Producing Party (and, if not the same person or entity, to the Designating Party) by the 30-day STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 11 n:\cxlit\li2011\111349\00708359.doc 1 deadline that (1) identifies (by category, where appropriate) all the Protected Material that was 2 returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts, 3 compilations, summaries, or any other format reproducing or capturing any of the Protected Material. 4 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, motion 5 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and 6 trial exhibits, expert reports, attorney work product, and consultant and expert work product, even if 7 such materials contain Protected Material. Any such archival copies that contain or constitute 8 Protected Material remain subject to this Stipulated Protective Order as set forth in Section 4, and this 9 Court will have continuing jurisdiction to enforce the terms of this Stipulated Protective Order. 10 11 IT IS SO STIPULATED. 12 Dated: October 26, 2011 13 MAYER BROWN LLP By: ______/s/ ____________________________ Jason Wrubleski Attorney for Plaintiff Local Search Association 14 15 16 Dated: October 26, 2011 17 By:______/s/ ____________________________ Christine Van Aken* Attorney for Defendants City and County of San Francisco, San Francisco Board of Supervisors, and San Francisco Mayor Edwin M. Lee 18 19 20 21 DENNIS J. HERRERA SAN FRANCISCO CITY ATTORNEY *THE FILER OF THIS DOCUMENT ATTESTS THAT CONCURRENCE IN THE FILING OF THIS DOCUMENT HAS BEEN OBTAINED FROM ALL SIGNATORIES. 22 ORDER 23 24 PURSUANT TO STIPULATION, IT IS SO ORDERED. 25 26 DATED: 10/27/11 27 ____________________________ HON. DONNA M. RYU UNITED STATES MAGISTRATE JUDGE 28 STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 12 n:\cxlit\li2011\111349\00708359.doc EXHIBIT A 1 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 3 4 I, , declare under penalty of perjury that I have read and 5 understand the Stipulated Protective Order that was issued by the United States District Court for the 6 Northern District of California on ________________ in the case of Local Search Association v. City 7 and County of San Francisco, et al., Case No. CV-11-2776 SBA. I agree to comply with and to be 8 bound by all the terms of this Stipulated Protective Order and I understand and acknowledge that 9 failure to so comply could expose me to sanctions and punishment in the nature of contempt. In 10 addition, I specifically understand and promise the following: 11 1. I will not disclose the CONFIDENTIAL INFORMATION to any other person. 12 2. I understand that I have no power to authorize any other person to review the CONFIDENTIAL INFORMATION. 13 14 3. I promise not to make copies of the CONFIDENTIAL INFORMATION. 15 4. I promise to return the CONFIDENTIAL INFORMATION to counsel for the party that provided it to me, at or before the conclusion of this litigation. 16 17 I further agree to submit to the jurisdiction of the United States District Court for the Northern 18 District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if 19 such enforcement proceedings occur after termination of this action. 20 21 _________________________ DATE SIGNATURE 22 _____________________ PRINT NAME 23 ______________________________________ CITY AND STATE WHERE SWORN/SIGNED 24 25 26 27 28 STIPULATION & ORDER CASE NO. CV-11-2776 SBA (DMR) 13 n:\cxlit\li2011\111349\00708359.doc

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