Plushy Feely Corp. v. Gaul

Filing 29

STIPULATED PROTECTIVE ORDER (MODIFIED BY THE COURT). Signed by Magistrate Judge Howard R. Lloyd on March 18, 2013. (hrllc1, COURT STAFF) (Filed on 3/18/2013)

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*E-FILED: March 18, 2013*

ALLEN B. GRODSKY (SBN 111064)
GRODSKY & OLECKILLP
2001 Wilshire Blvd., Ste. 210
Santa Monica, California 90403
310.315.3009 (Qhone)
310.315.1557 (tax)
[e-mail]
Attorneys for Plaintiff and Counterdefendant
Pl,ushy Feely Cor_p. and Counterdefendant
Nma Rappaport-Rowan

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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PLUSHY FEELY CORP., a California
Corporation,

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Plaintiff,

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vs.

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RANDY GAUL, an individual,

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Defendant.

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No.: CV 12 04119 LHK (HRL)
Complaint Filed: August 3, 2012
Before the Hon. Lucy H. Koh
STIPULATED PROTECTIVE
ORDER
(MODIFIED BY THE COURT)

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1.

PURPOSES AND LIMITATIONS

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Disclosure and discovery activity in this action are likely to involve production
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of confidential, proprietary, or private information for which special protection from
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public disclosure and from use for any purpose other than prosecuting this litigation
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may be warranted. Accordingly, the parties hereby stipulate to and petition the court
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to enter the following Stipulated Protective Order. The parties acknowledge that this
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Order does not confer blanket protections on all disclosures or responses to discovery
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and that the protection it affords from public disclosure and use extends only to the
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limited information or items that are entitled to confidential treatment under the
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STIPULATED PROTECTIVE ORDER

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applicable legal principles. The parties further acknowledge, as set forth in Section

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12.3, below, that this Stipulated Protective Order does not entitle them to file

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confidential information under seal; Civil Local Rule 79-5 and General Order 62 set

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forth the procedures that must be followed and the standards that will be applied when

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a party seeks permission from the court to file material under seal.

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2.

DEFINITIONS

2.1

Challenging Party: a Party or Non-Party that challenges the designation

of information or items under this Order.
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"CONFIDENTIAL" Information or Items: information (regardless of

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how it is generated, stored or maintained) or tangible things that qualify for protection

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under Federal Rule of Civil Procedure 26(c).

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2.3

Counsel (without qualifier): Outside Counsel of Record and House

Counsel (as well as their support staff).
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Designating Party: a Party or Non-Party that designates infonnation or

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items that it produces in disclosures or in responses to discovery as

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"CONFIDENTIAL."

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2.5

Disclosure or Discovery Material: all items or information, regardless of

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the medium or manner in which it is generated, stored, or maintained (including,

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among other things, testimony, transcripts, and tangible things), that are produced or

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generated in disclosures or responses to discovery in this matter.

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2.6

Expert: a person with specialized knowledge or experience in a matter

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pertinent to the litigation who has been retained by a Party or its counsel to serve as an

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expert witness or as a consultant in this action.

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2.7

House Counsel: attorneys who are employees of a party to this action.

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House Counsel does not include Outside Counsel of Record or any other outside

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counsel.

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STIPULATED PROTECTIVE ORDER

2.8

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Non-Party: any natural person, partnership, corporation, association, or

other legal entity not named as a Party to this action.
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Outside Counsel of Record: attorneys who are not employees of a party

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to this action but are retained to represent or advise a party to this action and have

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appeared in this action on behalf of that party or are affiliated with a law finn which

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has appeared on behalf of that party.
2.10 Party: any party to this action, including all of its officers, directors,

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employees, consultants, retained experts, and Outside Counsel of Record (and their

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support staffs).
2.11 Producing Party: a Party or Non-Party that produces Disclosure or

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Discovery Material in this action.
2.12 Professional Vendors: persons or entities that provide litigation support

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services (e.g., photocopying, videotaping, translating, preparing exhibits or

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demonstrations, and organizing, storing, or retrieving data in any form or medium) and

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their employees and subcontractors.
2.13 Protected Material: any Disclosure or Discovery Material that is

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designated as "CONFIDENTIAL."
2.14 Receiving Party: a Party that receives Disclosure or Discovery Material

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from a Producing Party.

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3.

SCOPE
The protections conferred by this Stipulation and Order cover not only Protected

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Material (as defined above), but also ( 1) any information copied or extracted from

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Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

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Material; and (3) any testimony, conversations, or presentations by Parties or their

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Counsel that might reveal Protected Material. However, the protections conferred by

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this Stipulation and Order do not cover the following information: (a) any information

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that is in the public domain at the time of disclosure to a Receiving Party or becomes
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STIPULATED PROTECTIVE ORDER

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part of the public domain after its disclosure to a Receiving Party as a result of

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publication not involving a violation of this Order, including becoming part of the

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public record through trial or otherwise; and (b) any information known to the

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Receiving Party prior to the disclosure or obtained by the Receiving Party after the

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disclosure from a source who obtained the information lawfully and under no

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obligation of confidentiality to the Designating Party. Any use of Protected Material at

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trial shall be governed by a separate agreement or order.

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4.

DURATION

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Even after final disposition of this litigation, the confidentiality obligations

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imposed by this Order shall remain in effect until a Designating Party agrees otherwise

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in writing or a court order otherwise directs. Final disposition shall be deemed to be

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the later of ( 1) dismissal of all claims and defenses in this action, with or without

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prejudice; and (2) final judgment herein after the completion and exhaustion of all

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appeals, rehearings, remands, trials, or reviews of this action, including the time limits

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for filing any motions or applications for extension of time pursuant to applicable law.

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For a period of six months after final disposition of this litigation, this court will retain
jurisdiction to enforce the terms of this order.

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5.

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DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

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Each Party or Non-Party that designates information or items for protection under this

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Order must take care to limit any such designation to specific material that qualifies

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under the appropriate standards. The Designating Party must designate for protection

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only those parts of material, documents, items, or oral or written communications that

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qualify- so that other portions of the material, documents, items, or communications

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for which protection is not warranted are not swept unjustifiably within the ambit of

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this Order.

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STIPULATED PROTECTIVE ORDER

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Mass, indiscriminate, or routinized designations are prohibited. Designations

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that are shown to be clearly unjustified or that have been made for an improper

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purpose (e.g., to unnecessarily encumber or retard the case development process or to

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impose unnecessary expenses and burdens on other parties) expose the Designating

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Party to sanctions.

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If it comes to a Designating Party's attention that information or items that it

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designated for protection do not qualify for protection, that Designating Party must

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promptly notify all other Parties that it is withdrawing the mistaken designation.

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5.2

Manner and Timing of Designations. Except as otherwise provided in this

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Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated

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or ordered, Disclosure or Discovery Material that qualifies for protection under this

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Order must be clearly so designated before the material is disclosed or produced.

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Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic

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documents, but excluding transcripts of depositions or other pretrial or trial

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proceedings), that the Producing Party affix the legend "CONFIDENTIAL" to each

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page that contains protected material. If only a portion or portions of the material on a

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page qualifies for protection, the Producing Party also must clearly identify the

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protected portion(s) (e.g., by making appropriate markings in the margins).

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A Party or Non-Party that makes original documents or materials available for

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inspection need not designate them for protection until after the inspecting Party has

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indicated which material it would like copied and produced. During the inspection and

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before the designation, all of the material made available for inspection shall be

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deemed "CONFIDENTIAL." After the inspecting Party has identified the documents

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it wants copied and produced, the Producing Party must determine which documents,

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or portions thereof, qualify for protection under this Order. Then, before producing the

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specified documents, the Producing Party must affix the "CONFIDENTIAL" legend to

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STIPULATED PROTECTIVE ORDER

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each page that contains Protected Material. If only a portion or portions of the material

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on a page qualifies for protection, the Producing Party also must clearly identify the

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protected portion(s) (e.g., by making appropriate markings in the margins).
(b) for testimony given in deposition or in other pretrial or trial

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proceedings, that the Designating Party identify on the record, before the close of the

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deposition, hearing, or other proceeding, all protected testimony.
(c) for information produced in some form other than documentary and

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for any other tangible items, that the Producing Party affix in a prominent place on the

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exterior of the container or containers in which the information or item is stored the

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legend "CONFIDENTIAL." If only a portion or portions of the information or item

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warrant protection, the Producing Party, to the extent practicable, shall identify the

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protected portion(s).
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Inadvertent Failures to Designate. If timely corrected, an inadvertent

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failure to designate qualified information or items does not, standing alone, waive the

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Designating Party's right to secure protection under this Order for such material.

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Upon timely correction of a designation, the Receiving Party must make reasonable

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efforts to assure that the material is treated in accordance with the provisions of this

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Order.

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6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Timing of Challenges. Any Party or Non-Party may challenge a

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designation of confidentiality at any time. Unless a prompt challenge to a Designating

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Party's confidentiality designation is necessary to avoid foreseeable, substantial

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unfairness, unnecessary economic burdens, or a significant disruption or delay of the

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litigation, a Party does not waive its right to challenge a confidentiality designation by

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electing not to mount a challenge promptly after the original designation is disclosed.

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STIPULATED PROTECTIVE ORDER

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6.2

Meet and Confer. The Challenging Party shall initiate the dispute

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resolution process by providing written notice of each designation it is challenging and

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describing the basis for each challenge. To avoid ambiguity as to whether a challenge

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has been made, the written notice must recite that the challenge to confidentiality is

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being made in accordance with this specific paragraph of the Protective Order. The

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parties shall attempt to resolve each challenge in good faith and must begin the process

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by conferring directly (in voice to voice dialogue; other forms of communication are

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not sufficient) within 14 days of the date of service of notice. In conferring, the

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Challenging Party must explain the basis for its belief that the confidentiality

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designation was not proper and must give the Designating Party an opportunity to

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review the designated material, to reconsider the circumstances, and, if no change in

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designation is offered, to explain the basis for the chosen designation. A Challenging

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Party may proceed to the next stage of the challenge process only if it has engaged in

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this meet and confer process first or establishes that the Designating Party is unwilling

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to participate in the meet and confer process in a timely manner.

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6.3

Judicial Intervention. If the Parties cannot resolve a challenge without
parties shall comply with the undersigned's Standing Order re

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court intervention, the Designating Party shall file and serve a motion to retain

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confidentiality under Civil Local Rule 7 (and in compliance with Civil Local Rule 79-5

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and General Order 62, if applicable) within 21 days of the initial notice of challenge or

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within 14 days of the parties agreeing that the meet and confer process will not resolve

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their dispute, whichever is earlier. Each such motion must be accompanied by a

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competent declaration affirming thatthe movant has complied with the meet and

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confer requirements imposed in the preceding paragraph. Failure by the Designating

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Party to make such a motion including the required declaration within 21 days (or 14

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days, if applicable) shall automatically waive the confidentiality designation for each

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challenged designation. In addition, the Challenging Party may file a motion

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challenging a confidentiality designation at any time if there is good cause for doing

Civil Discovery Disputes

Any Discovery Dispute Joint Report shall affirm that

have been satisfied.
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seek judicial intervention

seek relief with respect to

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STIPULATED PROTECTIVE ORDER

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so, including a challenge to the designation of a deposition transcript or any portions

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thereof. Any motion brought pursuant to this provision must be accompanied by a

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competent declaration affirming that the movant has complied with the meet and

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confer requirements imposed by the preceding paragraph.
The burden of persuasion in any such challenge proceeding shall be on the

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Designating Party. Frivolous challenges, and those made for an improper purpose

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(e.g., to harass or impose unnecessary expenses and burdens on other parties) may

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expose the Challenging Party to sanctions. Unless the Designating Party has waived

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the confidentiality designation by failing to file a motion to retain confidentiality as

seek relief

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described above, all parties shall continue to afford the material in question the level of

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protection to which it is entitled under the Producing Party's designation until the court

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rules on the challenge.

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7.

ACCESS TO AND USE OF PROTECTED MATERIAL

7.1

Basic Principles. A Receiving Party may use Protected Material that is

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disclosed or produced by another Party or by a Non-Party in connection with this case

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only for prosecuting, defending, or attempting to settle this litigation. Such Protected

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Material may be disclosed only to the categories of persons and under the conditions

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described in this Order. When the litigation has been tenninated, a Receiving Party

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must comply with the provisions of section 13 below (FINAL DISPOSITION).

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Protected Material must be stored and maintained by a Receiving Party at a

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location and in a secure manner that ensures that access is limited to the persons

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authorized under this Order.

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7.2

Disclosure of"CONFIDENTIAL" Information or Items. Unless

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otherwise ordered by the court or permitted in writing by the Designating Party, a

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Receiving Party may disclose any information or item designated "CONFIDENTIAL"

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only to:

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STIPULATED PROTECTIVE ORDER

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(a) the Receiving Party's Outside Counsel of Record in this action, as

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well as employees of said Outside Counsel of Record to whom it is reasonably

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necessary to disclose the information for this litigation and who have signed the

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"Acknowledgment and Agreement to Be Bound" that is attached hereto as Exhibit A;

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(b) the Receiving Party and the officers, directors, and employees

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(including House Counsel) of the Receiving Party to whom disclosure is reasonably

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necessary for this litigation and who have signed the "Acknowledgment and

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Agreement to Be Bound" (Exhibit A);

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(c) Experts (as defined in this Order) of the Receiving Party to whom

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disclosure is reasonably necessary for this litigation and who have signed the

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"Acknowledgment and Agreement to Be Bound" (Exhibit A);

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(d) the court and its personnel;

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(e) court reporters and their staff, professional jury or trial consultants,

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.mock jurors, and Professional Vendors to whom disclosure is reasonably necessary for

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this litigation and who have signed the "Acknowledgment and Agreement to Be

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Bound" (Exhibit A);

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(f) during their depositions, witnesses in the action to whom disclosure is

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reasonably necessary and who have signed the "Acknowledgment and Agreement to

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Be Bound" (Exhibit A), unless otherwise agreed by the Designating Party or ordered

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by the court. Pages of transcribed deposition testimony or exhibits to depositions that

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reveal Protected Material must be separately bound by the court reporter and may not

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be disclosed to anyone except as permitted under this Stipulated Protective Order.

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(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information.

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STIPULATED PROTECTIVE ORDER

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PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
IN OTHER LITIGATION

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If a Party is served with a subpoena or a court order issued in other litigation that

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compels disclosure of any information or items designated in this action as

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"CONFIDENTIAL," that Party must:

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(a) promptly notify in writing the Designating Party. Such notification
shall include a copy of the subpoena or court order;

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(b) 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

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or order is subject to this Protective Order. Such notification shall include a copy of

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this Stipulated Protective Order; and

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(c) cooperate with respect to all reasonable procedures sought to be
pursued by the Designating Party whose Protected Material may be affected.

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If the Designating Party timely seeks a protective order, the Party served with

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the subpoena or court order shall not produce any information designated in this action

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as "CONFIDENTIAL" before a determination by the court from which the subpoena

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or order issued, unless the Party has obtained the Designating Party's permission. The

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Designating Party shall bear the burden and expense of seeking protection in that court

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of its confidential material - and nothing in these provisions should be construed as

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authorizing or encouraging a Receiving Party in this action to disobey a lawful

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directive from another court.

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9.

A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(a)

The terms of this Order are applicable to information produced by a

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Non-Party in this action and designated as "CONFIDENTIAL." Such information
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produced by Non-Parties in connection with this litigation is protected by the remedies
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STIPULATED PROTECTIVE ORDER

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and relief provided by this' Order. Nothing in these provisions should be construed as

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prohibiting a Non-Party from seeking additional protections.
(b)

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In the event that a Party is required, by a valid discovery request, to

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produce a Non-Party's confidential information in its possession, and the Party is

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subject to an agreement with the Non-Party not to produce the Non-Party's

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confidential information, then the Party shall:
( 1)

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promptly notify in writing the Requesting Party and the Non-

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Party that some or all of the information requested is subject to a confidentiality

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agreement with a Non-Party;
(2)

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promptly provide the Non-Party with a copy of the Stipulated

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Protective Order in this litigation, the relevant discovery request(s), and a reasonably

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specific description of the information requested; and
(3)

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make the information requested available for inspection by

the Non-Party.
(c)

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If the Non-Party fails to object or seek a protective order from this

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court within 14 days of receiving the notice and accompanying information, the

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Receiving Party may produce the Non-Party's confidential information responsive to

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the discovery request. If the Non-Party timely seeks a protective order, the Receiving

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Party shall not produce any infonnation in its possession or control that is subject to

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the confidentiality agreement with the Non-Party before a determination by the court. 1

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Absent a court order to the contrary, the Non-Party shall bear the burden and expense

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of seeking protection in this court of its Protected Material. See Paragraph 14.

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The purpose of this J2rovision is to alert the interested parties to the existence of
confidentiality rights of a Non-Party and to afford the Non-Party an opportunity to
protect its confidentiality interests in this court.
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STIPULATED PROTECTIVE ORDER

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10.

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UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
Protected Material to any person or in any circumstance not authorized under this
Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
all unauthorized copies of the Protected Material, (c) inform the person or persons to
whom unauthorized disclosures were made of all the terms ofthis Order, and (d)
request such person or persons to execute the "Acknowledgment and Agreement to Be
Bound" that is attached hereto as Exhibit A.

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11.

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When a Producing Party gives notice to Receiving Parties that certain

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INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL

inadvertently produced material is subject to a claim of privilege or other protection,
the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
Procedure 26(b )(5)(B). This provision is not intended to modify whatever procedure
may be established in an e-discovery order that provides for production without prior
privilege review. Pursuant to Federal Rule of Evidence 502( d) and (e), insofar as the
parties reach an agreement on the effect of disclosure of a communication or
information covered by the attorney-client privilege or work product protection, the
parties may incorporate their agreement in the stipulated protective order submitted to
the court.

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12.

MISCELLANOUS

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 Party waives any right it otherwise would have to object to
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STIPULATED PROTECTIVE ORDER

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disclosing or producing any information or item on any ground not addressed in this

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Stipulated Protective Order. Similarly, no Party waives any right to object on any

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ground to use in evidence of any of the material covered by this Protective Order.

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12.3 Filing Protected Material. Without written permission from the

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Designating Party or a court order secured after appropriate notice to all interested

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persons, a Party may not file in the public record in this action any Protected Material.

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A Party that seeks to file under seal any Protected Material must comply with Civil

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Local Rule 79-5 and General Order 62. Protected Material may only be filed under

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seal pursuant to a court order authorizing the sealing of the specific Protected Material

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at issue. Pursuant to Civil Local Rule 79-5 and General Order 62, a sealing order will

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issue only upon a request establishing that the Protected Material at issue is privileged,

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protectable as a trade secret, or otherwise entitled to protection under the law. If a

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Receiving Party's request to file Protected Material under seal pursuant to Civil Local

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Rule 79-5( d) and General Order 62 is denied by the court, then the Receiving Party

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may file the information in the public record pursuant to Civil Local Rule 79-5(e)

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unless otherwise instructed by the court.

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13.

FINAL DISPOSITION
Within 60 days after the final disposition of this action, as defined in paragraph

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4, each Receiving Party must return all Protected Material to the Producing Party or

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destroy such material. As used in this subdivision, "all Protected Material" includes all

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copies, abstracts, compilations, summaries, and any other format reproducing or

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capturing any of the Protected Material. Whether the Protected Material is returned or

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destroyed, the Receiving Party must submit a written certification to the Producing

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Party (and, if not the same person or entity, to the Designating Party) by the 60 day

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deadline that (1) identifies (by category, where appropriate) all the Protected Material

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that was returned or destroyed and (2)affirms that the Receiving Party has not retained

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STIPULATED PROTECTIVE ORDER

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any copies, abstracts, compilations, summaries or any other format reproducing or

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capturing any of the Protected Material. Notwithstanding this provision, Counsel are

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entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and

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hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits,

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expert reports, attorney work product, and consultant and expert work product, even if

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such materials contain Protected Material. Any such archival copies that contain or

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constitute Protected Material remain subject to this Protective Order as set forth in

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Section 4 (DURATION).

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**

IT !S.~O STIPULATED, THROUGH CO.rtl~L n.~· fj-ECORD.

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DATED:.

~ -t'"t-t~

()L{;(ll~
Attorneys for Plaintiff

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AS MODIFIED BY THE COURT,

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PURSUANT TO STIPULATION:·1T IS SO ORDERED.
^

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DATED:

March 18, 2013

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[Name of Judge]
United States District/Magistrate Judge
Howard R. Lloyd
United States Magistrate Judge

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** 14. In the event of any discovery or disclosure dispute, the parties and any affected
non-parties shall comply with the undersigned's Standing Order re Civil Discovery
Disputes.

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STIPULATED PROTECTIVE ORDER

EXHIBIT A

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ACKNO~EDGMffiNTANDAGREEMENTTOBEBOUND

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I , - - - - - - - - - - - - - [print or type full name], of
[print or type full address], declare under penalty of perjury that I

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have read in its entirety and understand the Stipulated Protective Order that was issued

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by the United States District Court for the Northern District of California on [date] in

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the case of Plush Feely Corp. v. Gaul, CV 12 4119 LHK (HRL). I agree to comply

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with and to be bound by all the terms of this Stipulated Protective Order and I

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understand and acknowledge that failure to so comply could expose me to sanctions

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and punishment in the nature of contempt. I solemnly promise that I will not disclose

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in any manner any information or item that is subject to this Stipulated Protective

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Order to any person or entity except in strict compliance with the provisions of this

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Order.
I further agree to submit to thejurisdiction of the United States District

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Court for the Northern District of California for the purpose of enforcing the terms of

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this Stipulated Protective Order, even if such enforcement proceedings occur after

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termination of this action.
I hereby appoint _ _ _ _ _ _ _ _ _ _ _ [print or type full name]

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of

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telephone number] as my California agent for service of process in connection with

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this action or any proceedings related to enforcement of this Stipulated Protective

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Order.

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Date:

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City and State where sworn and signed: ------------------~

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[print or type full address and

--------------------------

Printed name:
--------------[printed name]
Signature: __________________
[signature]

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STIPULATED PROTECTIVE ORDER