MSPBO, LLC v. Adidas North America, Inc. et al

Filing 31

PROTECTIVE ORDER by Magistrate Judge Kathleen M. Tafoya on 12/23/13. (sgrim)

IN THE UNITED STATES DISTRICT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:13-cv-02287-PAB
MSPBO, LLC
Plaintiff,
v.

ADIDAS NORTH AMERICA, INC.,
ADIDAS AMERICA, INC.,
Defendants.

STIPULATED PROTECTIVE ORDER

The parties agree that certain information subject to discovery in this action may contain
trade secrets or other confidential, proprietary and/or commercially sensitive information. In the
interest of protecting that information and permitting discovery to proceed without delay
occasioned by disputes regarding such information, the parties agree to the protective provisions
set forth below. In view of these stipulations, and good cause appearing, the Court enters this
Protective Order pursuant to Federal Rule of Civil Procedure 26(c).
IT IS ORDERED:
1.

This Confidentiality Agreement and Protective Order (“Protective Order”) shall

govern (i) any designated record of documentation, things or information which is produced by
any Party during settlement discussions, as well as any communication or information which is
relayed or exchanged by any party during such settlement discussions and (ii) any designated
record of documentation, things, information, and any evidence and any form of discovery

contemplated under the Federal Rules of Civil Procedure of any type, kind or character produced
in this action, including without limitation the initial pleadings, briefs, memoranda, exhibits or
other writings filed with the Court, all designated deposition testimony, all designated testimony
taken at a hearing or other proceeding, interrogatory answers, documents (including electronic
documents in any form), things and other discovery materials, whether produced informally or in
response to interrogatories, requests for admission, requests for production of documents, or
other formal method of discovery (collectively, “Confidential Information”).
2.

Except as provided, the Parties and their counsel agree that Confidential

Information may be designated as either “Confidential” or “Confidential – Outside Attorneys’
Eyes Only,” (as defined in paragraph 7, below) or a designation substantially similar. Upon a
designation of confidentiality, the Confidential Information shall be used only for purposes
necessary to the litigation, settlement of claims, or related activity between and among the parties
in this action (a “Permitted Purpose”), and not for any commercial, business, competitive, or
other purpose (including for the purpose of filing or prosecuting patent applications).
3.

Documents designated as “Confidential” or “Confidential – Outside Attorneys’

Eyes Only” shall include (a) all copies, extracts and complete or partial summaries prepared
from such documents or information; (b) portions of pleadings which contain, summarize or
reflect the content of any such documents, copies, extracts, or summaries, (c) portions of
deposition transcripts and exhibits which contain, summarize or reflect the content of any such
documents, copies, extracts, or summaries; (d) portions of briefs, memoranda, exhibits or any
other writings filed with the Court which contain, summarize or reflect the content of any such
document, copies, extracts, or summaries; (e) deposition testimony designated in accordance

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with paragraph 4 below; and (f) testimony taken at a hearing or other proceeding that is
designated in accordance with paragraphs 5 and 22 below.
4.

Information disclosed or testimony elicited at a deposition may be designated as

Confidential Information by either (i) identifying on the record at the deposition those portions of
the testimony which are Confidential Information, or (ii) notifying in writing all parties to this
Protective Order within thirty (30) days of the date of receipt of the deposition transcript or the
date of this Order, whichever is later, those pages and lines of the transcript considered to be
Confidential Information. After the thirty (30) day period has elapsed, deposition testimony can
only be designated as Confidential Information upon agreement of the parties or order of the
Court.

During the thirty (30) days after each deposition or the date of this Order,

unless otherwise agreed by the parties in particular cases, the entire transcript shall be
considered as “Confidential – Outside Attorneys’ Eyes Only” and shall not be disclosed to
any person other than those described in Paragraph 9 below and the deponent. Upon being
informed that certain portions of deposition testimony are to be designated Confidential
Information, all parties shall immediately mark each copy of the transcript in its custody or
control and limit disclosure of the transcript in accordance with Paragraphs 9 and 10 below.
5.

With respect to testimony elicited during hearings and other proceedings,

whenever counsel for any party deems that any question or line of questioning calls for the
disclosure of information that should be kept “Confidential” or “Confidential – Outside
Attorneys’ Eyes Only,” counsel may move to close the proceedings pursuant to D.C. Colo. L.
Civ. R. 7.2.
6.

Any document, material, or information designated by a party as Confidential

Information must be reviewed by an attorney. The designation of any document, material, or

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information as Confidential Information, in the manner described, shall constitute a
certification by the attorney reviewing the material and making such designation that he or she in
good faith believes the material is confidential or otherwise entitled to protection under Fed. R.
Cir. P. 26(c)(7).

The parties shall endeavor to limit the use of the “Confidential” or

“Confidential – Outside Attorneys’ Eyes Only” designations to those documents and materials
that genuinely warrant the protection provided under the terms of this Protective Order.
7.

A party will make a Confidential Information designation, as is appropriate, only

to that information that contains or reflects such party's trade secrets, confidential or proprietary
information, or information covered by a legitimate privacy right or interest of such party or of
that party's customers, employees or agents or as to which a third party has provided documents,
information or other material with the understanding that it will be kept confidential. The
designation “Confidential – Outside Attorneys’ Eyes Only” shall be limited to Confidential
Information which is (i) highly sensitive, confidential research, development and other technical
information (including without limitation software code) and/or (ii) highly sensitive, confidential
financial and business information.
8.

Documents containing Confidential Information may be designated as

“Confidential” or “Confidential – Outside Attorneys’ Eyes Only” by the producing party at the
time the document is produced or served by marking each page of the whole document which
contains Confidential Information with the appropriate designation.
9.

Except as otherwise provided by written stipulation of the parties or by further

order of the Court, information designated “Confidential” may be disclosed by the party
receiving such information on a need-to-know basis only to:
a. The Court and court personnel;

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b. Outside counsel of record retained by a Party to the extent necessary for the
Permitted Purpose, including the employees of such counsel necessary to assist such
counsel in this action, to the extent that counsel is not presently serving and has not
served as an officer or manager of Phat Rat Technology, Inc., Phat Rat Technology,
LLC, MSPBO, LLC, or Civix-DDI, LLC;
c.

One officer, employee, agent or in-house counsel of each Party to the extent
necessary for the Permitted Purpose;

d. Expert witnesses or consultants retained by the parties or counsel of record in
connection with this Litigation, but only to the extent necessary for the Permitted
Purpose, provided that:
i. The name, address, current employment (if any) and curriculum vitae, including
a statement of prior expert testimony of any such expert or consultant over the
last five (5) years, shall be furnished to counsel of record for the other parties
more than five (5) business days before access to the Confidential Information
may be given to such expert or consultant;
ii. The other party or parties shall have five (5) business days after receipt of the
information called for in subparagraph (i) above to raise an objection and notify
the receiving party, in writing, that the producing party objects to disclosing
Confidential Information to such expert or consultant. Such notification shall
include the basis of the objection. The parties shall then confer, immediately
and in good faith, to resolve the conflict.

If the parties cannot resolve the

conflict, the receiving party may move the Court for an order allowing the

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requested disclosures, but no disclosure shall be made until the Court rules in
favor of the receiving party; and
iii. Before access is given, such expert or consultant signs a Confidentiality
Certificate in the form attached as Exhibit A.
e.

Any court reporter, typist or videographer providing services for recording or
transcribing testimony in this action or any outside independent reproduction or
graphics firm rendering reproduction or graphics services in this action;

f. Witnesses at depositions or trial, and their counsel, subject to the provisions of
paragraph 17, below, and provided that no copies of such information shall be given
to such witness or the witness' counsel to retain; and
g.

Such other persons as agreed to in writing by the parties or as determined by the
Court after notice and hearing to all parties.

10.

Except as otherwise provided by written stipulation of the Parties or by further

order of the Court, information designated “Confidential – Outside Attorneys’ Eyes Only” may
be disclosed by the party receiving such information on a need-to-know basis only to the persons
identified in paragraphs 9(a), (b), (d), (e), (f) and (g), subject to the restrictions (if any) set forth
in such paragraphs.

No documents or information designated “Confidential – Outside

Attorneys’ Eyes Only” by a Party shall be disclosed to any other Party to this action or to any
officer, director, employee, or agent of any other Party, except by written stipulation of such
parties or by order of the Court.
11.

To the extent a Producing Party’s Source Code is discoverable in this action, it

may be designated as “Source Code – Outside Attorneys’ Eyes Only – Restricted Confidential”

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and in addition to the protections of paragraphs 9-10, shall be subject to the following additional
restrictions and protections:
a.

Unless otherwise agreed by the Parties, permitted by the Federal Rules of Civil

Procedure, the Local Rules or the Court’s Scheduling Order, or otherwise ordered by the Court,
the producing party shall provide one standalone, non-networked computer (the “Source Code
Computer”) for the purpose of reviewing source code, running a reasonably current version of an
operating system, such as Microsoft Windows, Linux, or SunOS. The Producing Party and the
Receiving Party shall consult with one another in advance regarding particular Source Code
review tools to be installed on the computer and the Receiving Party shall be responsible for
bearing the cost and for providing the installation files of review tools.
b.

Unless otherwise agreed by the Parties, permitted by the Federal Rules of Civil

Procedure, the Local Rules or the Court’s Scheduling Order, or otherwise ordered by the Court,
source code shall be made available for inspection at the offices of counsel (which in the case of
Defendants, shall be at their counsel’s offices in Denver, Colorado) for the Producing Party
during regular business hours upon reasonable notice.
c.

Unless otherwise agreed by the Parties, permitted by the Federal Rules of Civil

Procedure, the Local Rules or the Court’s Scheduling Order, or otherwise ordered by the Court,
the Receiving Party shall provide ten (10) business days notice that it wishes to inspect Source
Code prior to the first inspection of any Source Code.
d.

To the extent permitted by the Federal Rules of Civil Procedure, the Local Rules,

the Court’s Scheduling order and other orders of the Court, the Producing Party may enforce
reasonable restrictions on the review of source code in electronic format, including making
source code available on a stand-alone, non-networked computer, with input/output connections

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disabled such that source code cannot be removed, copied, or otherwise transferred from the
Source Code Computer and the Source Code Computer cannot be connected to the Internet. Use
of any input/output device (e.g. USB memory stick, CDs, floppy disk, portable hard drive, etc.)
is prohibited while accessing the Source Code Computer. Under no circumstances is the Source
Code to be copied or transmitted in any form without the prior authorization of the Producing
Party, except as otherwise provided herein.
e.

Unless otherwise agreed by the Parties, permitted by the Federal Rules of Civil

Procedure, the Local Rules or the Court’s Scheduling Order, or otherwise ordered by the Court,
the Receiving Party shall identify all experts or consultants it requests be allowed access to the
source code at least seven (7) business days prior to any inspection, to permit the Producing
Party time to object. As part of the identification procedure, the Receiving Party shall provide
the Producing Party with the information set forth in paragraph 9(d) and shall also retain the
expert- or consultant-executed Exhibit A in its files.
f.

Unless otherwise agreed by the Parties, permitted by the Federal Rules of Civil

Procedure, the Local Rules or the Court’s Scheduling Order, or otherwise ordered by the Court,
the Receiving Party’s expert(s) and/or consultant(s) may take notes relating to the Source Code,
but may not copy any of the Source Code into the notes and may not take such notes
electronically on the Source Code Computer itself.
g.

Unless otherwise agreed by the Parties, permitted by the Federal Rules of Civil

Procedure, the Local Rules or the Court’s Scheduling Order, or otherwise ordered by the Court,
the Receiving Party may request certain portions of the Producing Party’s Source Code be
printed to paper copies, but shall not request printed copies to review blocks of Source Code.
The Receiving Party’s outside counsel of record may make no more than three (3) additional

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paper copies of any portions of Source Code. Any printed pages of source code, and any other
documents or things reflecting source code that have been designated by the Producing Party as
“Source Code – Outside Attorneys’ Eyes Only – Restricted Confidential” may not be digitally
imaged or otherwise duplicated, except to the extent the Court requires electronic filing of sealed
materials, electronic copies of such limited excerpts of source code as are reasonably needed for
use as exhibits to court filings. Any court filings including Source Code shall be filed under seal.
Expert reports may refer to source code by Bates number and may reproduce limited excerpts of
source code in the report itself as needed to identify or discuss specific source code on a Bates
numbered page; however, expert reports shall not attach copies of source code as exhibits.
h.

Unless otherwise agreed by the Parties, or permitted by the Federal Rules of Civil

Procedure, the Local Rules or the Court’s Scheduling Order, or otherwise ordered by the Court,
the Receiving Party will not print, copy, remove, or otherwise transfer any Source Code from the
Source Code Computer including, without limitation, copying, removing, or transferring the
Source Code onto any recordable media or recordable device.
i.

The Receiving Party’s outside counsel of record and any person receiving a copy

of any Source Code shall maintain and store any paper copies of the Source Code at their offices
in a manner that prevents duplication of or unauthorized access to the Source Code, including,
without limitation, storing the Source Code Computer and the Source Code in a locked room or
cabinet at all times when it is not in use and maintaining a log of all electronic or paper copies of
any portion of Source Code in its possession, including the names of the reviewers and/or
recipients of such copies.
12.

Absent written consent from the Producing Party, any individual who receives

access to “Confidential,” “Confidential - Outside Attorneys’ Eyes Only” or “Source Code –

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Outside Attorneys’ Eyes Only – Restricted Confidential” information shall not be involved in the
prosecution of patents or patent applications (including the patent asserted in this action and any
patent or application claiming priority to or otherwise related to the patent asserted in this action)
directed to the particular subject matter disclosed in such “Confidential,” “Confidential -Outside Attorneys’ Eyes Only” or “Source Code – Outside Attorneys’ Eyes Only – Restricted
Confidential” information before any foreign or domestic agency, including the United States
Patent and Trademark Office (“the Patent Office”).

For purposes of this paragraph,

“prosecution” means directly or indirectly drafting, amending, advising, or otherwise affecting
the scope or maintenance of patent claims. To avoid any doubt, “prosecution” as used in this
paragraph does not include representing or advising a party before a domestic or foreign agency
in connection with a reissue protest, ex parte reexamination, or inter partes review; though in
connection with any such reissue protest, ex parte reexamination, or inter partes review involving
the patent-in-suit, Outside Counsel for Plaintiffs shall not: (i) reveal any Defendants’ Protected
Material to any prosecuting reexamination counsel or agent; or (ii) consistent with Paragraph 2,
use any Defendant’s Protected Material for any purpose other than this litigation.

This

Prosecution Bar shall begin when access to “Confidential,” “Confidential - Outside Attorneys’
Eyes Only” or “Source Code – Outside Attorneys’ Eyes Only – Restricted Confidential”
information is first received by the affected individual and shall end two (2) years after the
settlement and dismissal of the Producing Party from this action or the final non-appealable
termination of this action.
13.

This Order shall not bar any counsel of record for a Party, in the course of

rendering advice to such Party with respect to this litigation, from conveying to such Party
counsel's evaluation in a general way of Confidential Information produced or exchanged;

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provided, however, that in rendering such advice and otherwise communicating with such Party,
the attorney shall not disclose the specific contents of the Confidential Information produced by
another Party, which disclosure would be contrary to the terms of this Protective Order.
14.

Prior to receiving Confidential Information, any person, other than those

identified in paragraph 9(a), (b), (e) and (f), to whom Confidential Information is disclosed shall
acknowledge, by signing a copy of the attached Exhibit A, that he/she has read this Protective
Order and agrees to be bound by its terms. The original executed copy of Exhibit A shall be
maintained by the attorney who provides the Confidential Information to any person described
in paragraphs 9 and 10 above and that attorney has a duty to reasonably ensure that such person
complies with the terms of this Protective Order.
15.

This Protective Order does not affect the rights of the Parties with respect to their

own documents or information. The production of any Confidential Information shall not
constitute an admission by the producing party nor waive the producing party’s rights, with
respect to the propriety of its disclosure or its relevance. This Protective Order shall not preclude
any Party from designating and obtaining, on an appropriate showing, such additional protection
with respect to the confidentiality of documents or other discovery material as that party may
consider appropriate. Nor shall any Party be precluded from claiming, as set forth below, that
any matter designated is not entitled to the protections of this Protective Order, from applying to
the Court for an order permitting the disclosure or use of information or documents otherwise
prohibited by this Protective Order, or from applying for an order modifying this Protective
Order in any respect. No party shall be obligated to challenge the proprietary of any
confidentiality designation at the time of production and failure to do so shall not preclude a
subsequent attack on the propriety of such designation.

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16.

A party may object to the designation of Confidential Information by giving

written notice to the party designating the disputed information. The written notice shall identify
the information to which the objection is made. If the parties cannot resolve the objection within
ten (10) business days after the time the notice is received, it shall be the obligation of the party
designating the Confidential Information to file an appropriate motion requesting that the court
determine whether the disputed information should be subject to the terms of this Protective
Order. If such a motion is timely filed, the disputed information shall be treated as Confidential
Information under the terms of this Protective Order until the Court rules on the motion. If the
designating party fails to file such a motion within the prescribed time, the disputed information
shall lose its designation as Confidential Information and shall not be treated as Confidential
Information in accordance with this Protective Order. In connection with a motion filed under
this provision, the party designating the information as Confidential Information shall bear the
burden of establishing that good cause exists for the disputed information to be treated as
Confidential Information.
17.

In the event it becomes necessary to show any Confidential Information to a

witness at a deposition who is not authorized to see it as set forth in paragraphs 9 and 10 above,
the Confidential Information shall be disclosed to that witness only after the disclosing party
consents to the disclosure to the deposition witness and the witness acknowledges on the record
during that deposition that he/she read this Protective Order and agrees to be bound by its terms,
unless the witness is identified on the document as being an author, source or recipient of the
Confidential Information, the document refers or relates to the witness or the witness is
employed by the party who produced the Confidential Information, in which case the witness
may be questioned regarding the document. That portion of any deposition transcript, including

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attached exhibits, which discloses, pertains to, refers to, or incorporates Confidential Information
shall be treated according to the terms of this Protective Order and shall be deemed to be
Confidential Information.
18.

All Confidential Information filed with the Court shall be filed under seal in a

manner consistent with D. C. Colo. L. Civ. R. 7.2 and 7.3.
19.

This Protective Order shall be deemed to continue even after any litigation

between the parties terminates. Within sixty (60) days after the conclusion of this action,
including any appeals, all documents, objects, and other materials produced or designated by a
producing party as containing Confidential Information, and all reproductions, excerpts, notes,
summaries and digests, shall be returned to the producing party or shall be destroyed, at the
option of the party receiving such materials from a producing party. The receiving party
shall furnish to the other parties a certification that the Confidential Information has been
returned or destroyed; provided however, that counsel may retain one complete copy of all
transcripts, pleadings and memoranda, and exhibits, for archival purposes, subject to the
provisions of this Protective Order.
20.

Should a third-party seek access to Confidential Information, by request,

subpoena or otherwise, the subpoenaed party shall promptly notify all other parties so as to
provide the party whose Confidential Information is requested by the subpoena sufficient time to
seek a protective order before the information requested by the subpoena is produced.
Regardless of whether the Party whose Confidential Information is requested by the subpoena
seeks a protective order, the subpoenaed party shall not produce such Confidential Information
unless the subpoenaing parties agree to sign the Protective Order (restricting the use of the

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Confidential Information exclusively to their litigation) or unless the subpoenaed parties are
ordered to produce such Confidential Information by any court.
21.

Any dispute which arises under this Protective Order, including any effort

to contest the designation of Confidential Information as “Confidential” or “Confidential –
Outside Attorneys’ Eyes Only,” shall be resolved by motion made before the Court under the
Federal Rules of Civil Procedure and applicable local or court rules.
22.

Prior to the use of any Confidential Information at any hearing held in open court,

counsel desiring to use such Confidential Information shall provide reasonable notice to all
counsel executing this Protective Order and allow all counsel executing this Protective Order the
opportunity to object to the disclosure of Confidential Information in open court.
23.

The inadvertent or unintentional production or disclosure of Confidential

Information by a party owning such Confidential Information that should have been designated
"Confidential" or "Confidential—Outside Attorneys’ Eyes Only," regardless of whether the
information was so designated at the time of disclosure, shall not be deemed a waiver in whole or
in part of the party’s claim of confidentiality, either as to the specific information or document
disclosed or as to any other document or information containing the same or related subject
matter. Such inadvertent or unintentional disclosure may be rectified by notifying, in writing,
counsel for all parties to whom the material was disclosed or produced that the material should
be designated "Confidential" or "Confidential – Outside Attorneys’ Eyes Only." Such notice
shall constitute a designation of the information as Confidential Information under this
Protective Order and the receiving party shall either (i) mark all documents that include the
Confidential Information (including any documents provided by paragraph 3) with the

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appropriate designation and/or (ii) return the documents to the designating party so that the
designating party can affix the appropriate designations to the documents.
24.

The provisions of this Protective Order shall survive the conclusion of this

litigation, whether by settlement, judgment or otherwise, and shall continue in full force and
effect. The Court shall retain jurisdiction over the parties and any other person bound by this
Protective Order, to enforce this Protective Order.
25.

It is expressly contemplated and agreed that any non-party may invoke all

provisions of this Protective Order which are available to a producing party, and that the parties,
in accordance with the terms of this Protective Order, will treat as Confidential Information, all
information of a non-party that is designated as such in writing by the non-party, its
representative, or any party that in good faith believes such non-party’s information contains or
embodies its Confidential Information.
26.

Nothing contained in this Order shall be construed to require production of

Confidential Information deemed by counsel or record for the producing party to be privileged or
otherwise protected from discovery.
27.

Nothing contained in this Order shall be construed as (a) preventing a party from

using or continuing to use any information that is already known to the party, or which is or
becomes publicly known through no unauthorized act of such party, or (b) preventing a
party from using or continuing to use any information that is or becomes known to it if such
information was or is lawfully obtained by such party other than through discovery of the
producing party. Should a dispute arise as to any specific information or materials, the
burden shall be on the party claiming that such information or materials is or was publicly

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known or was lawfully obtained other than through discovery of the producing party.
DATED this 23rd day of December, 2013.

BY THE COURT:

_________________________
Kathleen M. Tafoya
United States Magistrate Judge
APPROVED:
/s/ David J. Sheikh __________
David J. Sheikh
NIRO, HALLER & NIRO
181 West Madison, Suite 4600
Chicago, IL 60602
[phone]
Fax: [phone]
Email: [e-mail]
Alexander C. Clayden
LATHROP & GAGE LLP
950 17th Street, Suite 2400
Denver, Colorado 80202
[phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff
MSPBO, LLC

/s/ Caroline A. Bader______________
Megan J. Redmond
Adam P. Seitz
Caroline A. Bader
ERISE IP, P.A.
6201 College Blvd., Suite 300
Overland Park, KS 66221
Email: [e-mail]
Email: [e-mail]
Paul R. Hart
ERISE IP, P.A.
5300 DTC Pkwy., Suite 210
Greenwood Village, CO 80111
[phone]
Email: [e-mail]
Matias Ferrario
Kilpatrick Townsend & Stockton LLP
1001 West Fourth Street
Winston-Salem, NC 27101-2400
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendant
Adidas North America, Inc., and
Adidas America, Inc.

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IN THE UNITED STATES DISTRICT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:13-cv-02287-PAB
MSPBO, LLC
Plaintiff,
v.

ADIDAS NORTH AMERICA, INC.,
ADIDAS AMERICA, INC.,
Defendants.

EXHIBIT A
UNDERTAKING REGARDING PROTECTIVE ORDER
I, ____________________________________________, declare that:
1.

My address is ___________________________________________________________.
My current employer is ___________________________________________________.
My current occupation is __________________________________________________.

2.

I have received a copy of the Protective Order in this action. I have carefully read and
understand the provisions of the Protective Order.

3.

I will comply with all of the provisions of the Protective Order. I will hold in confidence,
will not disclose any Protected Materials to anyone not qualified under the Protective
Order, and will use only for purposes of this action any information designated as
“Confidential,” “Confidential – Outside Attorneys’ Eyes Only,” or “Source Code –
Outside Attorneys’ Eyes Only – Restricted Confidential” that is disclosed to me.

4.

Promptly upon termination of these actions or after my involvement in these actions

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otherwise terminates, I will return all documents and things designated as “Confidential,”
“Confidential – Outside Attorneys’ Eyes Only,” or “Source Code – Outside Attorneys’
Eyes Only – Restricted Confidential” that came into my possession, and all documents
and things that I have prepared relating thereto, to the outside counsel for the party by
whom I am employed.
5.

I hereby submit to the jurisdiction of this Court for the purpose of enforcement of the
Protective Order in this action.
I declare under penalty of perjury that the foregoing is true and correct.
Signature ________________________________________
Name Printed _____________________________________
Date ____________________________________________

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