Connectu, Inc. v. Facebook, Inc. et al

Filing 366

MOTION to Seal by Facebook, Inc., Andrew McCollum, Dustin Moskovitz, Eduardo Saverin, Thefacebook LLC, Mark Zuckerberg. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Text of Proposed Order)(Chatterjee, I.)

EXHIBIT A

G. HOPISINS GUY, I11 (STATE BAR NO. 12481 1)
I. NEEL CHATTERJEE (STATE BAR NO. 173985)
MONTE COOPER (STATE BAR NO. 196746)
ROBERT D. NAGEL (STATE BAR NO. 2 11113)
JOSHUA H. WALKER (STATE BAR NO. 224940)
ORRICK, HERRINGTON & SUTCLIFFE LLP
1000 Marsh Road
Menlo Park, CA 94025
Telephone: [phone]
Facsimile:
650-6 14-7401

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IR. NELSOk

Attorneys for Plaintiff
FACEBOOK, INC.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SANTA CLARA

FACEBOOK, INC.,
Plaintiff,

v.
CONNECTU LLC, CAMERON
WINKLEVOSS, TYLER WINKLEVOSS,
HOWARD WINKLEVOSS, DIVYA
NARENDRA, AND DOES 1-25,
Defendants.

DOCSSVl 433570.3

CASE NO. 1105-CV-047381

STIPULATED PROTECTIVE ORDER

Disclosure and discovery activity in this Action are likely to involve production of
confidential, proprietary, or private information for which special protection from public
disclosure and from use for any purpose other than prosecuting this litigation would be warranted.
Accordingly, each of the parties, Plaintiff FaceBook, Inc. ("Plaintiff"), Defendants ConnectU
LLC, Cameron Winklevoss, Tyler Winklevoss, Howard Winklevoss, and Divya Narendra
(collectively "Defendants"), assert that the Parties to This Litigation possess information that one
or more parties contends is confidential. The Parties wish to ensure that such Confidential
Information shall not be used for any purpose other than This Litigation, shall not be made public,
and shall not be disseminated beyond the extent necessary for This Litigation. Accordingly, the
following procedure shall be adopted for the protection of the parties' respective Confidential
Information.
The Parties hereby stipulate to and petition the court to enter the following Stipulated
Protective Order ("Order"). The Parties acknowledge that this Order does not confer blanket
protections on all disclosures or responses to discovery and that the protection it affords extends
only to the limited information or items that are entitled under the applicable legal principles to
treatment as confidential. The Parties further acknowledge that this Order creates no entitlement
to file Confidential Information under seal; California Rules of Court 243.1 and 243.2 set forth
the procedures that must be followed and reflect the standards that will be applied when a Party
seeks permission from the court to file material under seal.
1.

DEFINITIONS

1.1

Party: any party to this action, including Plaintiff and Defendants and all of

their officers, directors, employees, consultants, retained experts, and outside counsel (and their
respective support staffs).

1.2

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

the medium or manner generated, stored, or maintained (including, among other things,
testimony, transcripts, or tangible things) that are produced or generated in disclosures or
responses to discovery in This Litigation.

1.3
DOCSSV 1 :433570.3

"Confidential" Information or Items: information (regardless of how
-2STIPULATED PROTECTNE ORDER

generated, stored or maintained) or tangible things that contain trade secrets or other confidential
research, development, commercial, or business information.
1.4

"Highly Confidential - Attorneys' Eyes Only" Information or Items:

extremely sensitive "Confidential Information or Items" whose disclosure to another Party or
non-party would create a substantial risk of serious injury that could not be avoided by less
restrictive means.
1.5

Receiving Party: a Party that receives Disclosure or Discovery Material

from a Producing Party.
1.6

Producing Party: a Party or non-party that produces Disclosure or

Discovery Material in this action.

1.7

design at in^ Party: a Party or non-party that designates information or

items that it produces in disclosures or in responses to discovery as "Confidential" or "fighly
Confidential - Attorneys' Eyes Only."
1.8

This Liti~ation:Case No. 1:05-CV-047381 currently pending in Superior

Court of the State of California between Facebook, Inc. and ConnectU LLC, Cameron
Winklevoss, Tyler Winklevoss, Howard Winklevoss, and Divya Narendra, as well as any future
lawsuits between the parties in the Superior Court of the State of California.
1.9

Massachusetts Litigation: Case No. 1:04-CV-11923 currently pending

between ConnectU LLC, Cameron Winklevoss, Tyler Winklevoss, and Divya Narendra, and
Facebook, Inc., Mark Zuckerberg, Eduardo Saverin, Dustin Moskovitz, Andrew McCollum, and
Christopher Hughes in the U.S. District Court for the District of Massachusetts.

The

Massachusetts Litigation is governed by a separate second stipulated protective order and not this
Order.
1.10

Protected Material: any Disclosure or Discovery Material that is designated

as "Confidential" or as "fighly Confidential - Attorneys' Eyes Only."
1.11

Outside Counsel: attorneys who are not employees of a Party but who are

retained to represent or advise a Party in this action.

1.12
DOCSSV 1 :433570.3

In-House Counsel: attorneys who are employees of a Party.
-3STIPULATED PROTECTIVE ORDER

1.13

Counsel (without qualifier): Outside Counsel and In-House Counsel (as

well as their support staffs).
1.14

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

pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert
witness or as a consultant in this action and who is not a current employee of a Party or of a
competitor of a Party's and who, at the time of retention, is not anticipated to become an
employee of a Party or a competitor of a Party. This definition includes any technical experts,
discovery experts, and professional jury or trial consultant retained in connection with This
Litigation.
1.15

Professional Vendors: persons or entities that provide litigation support

services (e.g., photocopying; videotaping; translating; preparing exhibits or demonstrations;
organizing, storing, retrieving data in any form or medium; etc.) and their employees and
subcontractors.
1.15

Return Material: Protected Material, including all copies, abstracts,

compilations, summaries or any other form of reproducing or capturing any of the Protected
Material.
2.

SCOPE

The protections conferred by this Stipulation and Order cover not only Protected Material,
but also any information copied or extracted therefrom, as well as all copies, excerpts, summaries,
or compilations thereof, plus testimony, conversations, or presentations by parties or counsel to or
in court or in other settings that might reveal Protected Material.
3.

DURATION

Even after the termination of This Litigation and all appeals therefrom, the confidentiality
obligations imposed by this Order shall remain in effect until a Designating Party agrees
otherwise in writing or a court order otherwise directs.
4.

DESIGNATING PROTECTED MATERIAL
4.1

Exercise of Restraint and Care in Designating Material for Protection.

Each Party or non-party that designates information or items for protection under this
DOCSSV1:433570.3
-4STIPULATED PROTECTNE ORDER

Order must take care to limit any such designation to specific material that qualify under the
appropriate standards. A Designating Party must take care to designate for protection only those
parts of material, documents, items, or oral or written communications that qualify - so that other
portions of the material, documents, items, or communications for which protection is not
warranted are not swept unjustifiably within the ambit of this Order.
Mass, indiscriminate, or mere boiler-plate designations are prohibited. Designations that
are shown to be clearly unjustified, or that have been made for an improper purpose (e.g., to
unnecessarily encumber or retard the case development process, or to impose unnecessary
expenses and burdens on other parties), expose the Designating Party to sanctions.
If it comes to a Party's or a non-party's attention that information or items that it
designated for protection do not qualify for protection at all, or do not qualify for the level of
protection initially asserted, that Party or non-party must promptly notify all other parties that it is
withdrawing the designation.
4.2

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

Order, or as otherwise stipulated or ordered, material that qualifies for protection under this Order
must be clearly so designated before the material is disclosed or produced.
Designation in conformity with this Order requires:
(a)

for information in documentary form (apart from transcripts of

depositions or other pretrial or trial proceedings), that the Producing Party affix the legend
"Confidential" or "Highly Confidential - Attorneys' Eyes Only" on each page that contains
material to be protected. If only a portion or portions of the material on a page qualifies for
protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making
appropriate markings in the margins) and must specify, for each portion to be protected, the level
of protection being asserted (either "Confidential" or "Highly Confidential

-

Attorneys' Eyes

A Party or non-party that makes original documents or materials available for

inspection need not designate them for protection until after the inspecting Party has indicated
which material it would like copied and produced. During the inspection and before the
DOCSSV 1:433570.3
-5STIPULATED PROTECTIVE ORDER

designation, all of the material made available for inspection shall be deemed "Highly
Confidential - Attorneys' Eyes Only." After the inspecting Party has identified the documents it
wants copied and produced, the Producing Party must determine which documents, or portions
thereof, qualify for protection under this Order. Then, before producing the specified documents,
the Producing Party must affix the appropriate legend ("Confidential" or "Highly Confidential Attorneys' Eyes Only") on each page that contains material to be protected. If only a portion or
portions of the material on a page qualifies for protection, the Producing Party also must clearly
identify the protected portion(s) (e.g., by making appropriate markings in the margins) and must
specify, for each portion, the level of protection being asserted (either "Confidential7'or "Highly
Confidential - Attorneys' Eyes Only").
(b)

for testimony given in deposition or in other pretrial or trial proceedings,

that the Party or non-party offering or sponsoring the testimony identify on the record, before the
close of the deposition, hearing, or other proceeding, protected testimony, and further specify any
portions of the testimony that qualify as "Highly Confidential - Attorneys' Eyes Only." When it
is impractical to identify separately each portion of testimony that is entitled to protection, and
when it appears that substantial portions of the testimony may qualify for protection, the Party or
non-party that sponsors, offers, or gives the testimony may invoke on the record (before the
deposition or proceeding is concluded) a right to have up to thirty (30) days after the receipt of
the written transcript to identify the specific portions of the testimony as to which protection is
sought and to specify the level of protection being asserted ("Confidential" or "Highly
Confidential - Attorneys' Eyes Only").

Only those portions of the testimony that are

appropriately designated for protection within the thirty (30) days shall be covered by the
provisions of this Order.
Transcript pages containing Protected Material must be separately bound by the court
reporter, who must affix on each such page the legend "Confidential" or "Highly Confidential Attorneys' Eyes Only," as instructed by the Party or non-party offering or sponsoring the witness
or presenting the testimony.

(c)
DOCSSV I :433570.3

for information produced in some form other than documentary, and for
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6-

STIPULATED PROTECTNE ORDER

any other tangible items, that the Producing Party affix in a prominent place on the exterior of the
container or containers in which the information or item is stored the legend "Confidential" or
"Highly Confidential - Attorneys' Eyes Only." If only portions of the information or item
warrant protection, the Producing Party, to the extent practicable, shall identify the protected
portions, specifying whether they qualify as "Confidential7' or as "Highly Confidential Attorneys7Eyes Only."
(d)

for information produced by former employees of a party, the Receiving

Party shall treat all such information as "Confidential" unless and until:
(i)

the information has been or is obtained through other proper means;

(ii)

the former employing Party agrees that the information is not

(iii)

the Receiving Party successfully challenges the "Confidential"

"Confidential";

designation under Section 5; or
(iv)

a court of competent jurisdiction decides that the information is not

"Confidential."
4.3

Computer Source Code and Similar Electronic Media.

(a)

As used herein, "Computer Source Code" shall mean statements for the

programming of computers written in a high-level or assembly language that are readable by
humans but are not directly readable by a computer. Any person may specially designate as
''H~ghly Confidential - Attorneys' Eyes Only" any Computer Source Code or other similar
extremely sensitive technical materials (whether in electronic or hardcopy form) that it produces
in the course of discovery in This Litigation when such person has a good faith belief that such
material qualifies for such protection under this Order and that access to such materials would
allow replication of an otherwise confidential computer program. Except as otherwise provided
herein, "Highly Confidential - Attorneys' Eyes Only" designation made for this reason shall be
subject to all of the same restrictions as all other materials so designated with the following

1

I

additional restrictions:
(i)
DOCSSV1:433570.3

If a person is requested to produce electronic copies of material
-7STIPULATED PROTECTIVE ORDER

properly designated as "Highly Confidential - Attorneys' Eyes Only" under Section 4.3(a), any
such production shall be made on CD. The disclosing person shall provide to the receiving party
at least two (2) identical CD's containing the requested materials.
(ii)
"Highly Confidential

The Receiving Party shall not make copies in any medium of any

- Attorneys'

Eyes Only" under Section 4.3(a) except as follows:
At any given time, the Receiving Party may copy each

(1)

produced copy of "H~ghlyConfidential - Attorneys' Eyes Only" under Section 4.3(a) only into
the RAM of a single computer. Without limiting the generality of the foregoing, a particular copy
may not be copied into the RAM of one computer and then, while leaving that copy on the first
computer, subsequently copied into the RAM of another computer without prior written approval
from counsel for the disclosing person.
Any computer into whose RAM material properly

(2)

designated as "Highly Confidential

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Attorneys' Eyes Only7' material is copied must be

disconnected from any and all networks before the material is copied onto the computer and for
the duration of the time the material remains on the computer. Only after all such material is
removed from RAM and that computer has been shut down may any network connection be made
l

or restored.
(3)

I

1

Any computer into whose RAM material properly

designated as "Highly Confidential

-

Attorneys' Eyes Only" is copied must remain in the direct

control only of those persons specified in Section 6.3 of this Order as properly having access to
"Highly Confidential - Attorneys' Eyes Only" material.
(4)

Except for transitory copies created in the RAM or other

internal operating circuitry of a computer, excerpts of material properly designated as "Highly
Confidential - Attorneys' Eyes Only" shall be copied onto paper or electronic media only for the

1

1

purpose of creating submissions to the Court for presentation to the Court at hearings or at trial,
and, once having been made, all such excerpts of such material shall be designated "Highly
Confidential - Attorneys' Eyes Only" in the name of the disclosing person.

I

4.4
DOCSSV1:433570.3

Inadvertent Failures to Designate. Notwithstanding Section 5.2 below, if
-8STIPULATED PROTECTIVE ORDER

timely corrected, an inadvertent failure to designate qualified information or items as
"Confidential" or "Highly Confidential - Attorneys' Eyes Only" does not, standing alone, waive
the Designating Party's right to secure protection under this Order for such material. If material
is appropriately designated as "Confidential" or "Highly Confidential - Attorneys' Eyes Only"
after the material was initially produced, the Receiving Party, on timely notification of the
designation, must make reasonable efforts to assure that the material is treated in accordance with
the provisions of this Order.
5.

CHALLENGING PROTECTED MATERIAL DESIGNATIONS

5.1

Timing of Challen~es.Unless a prompt challenge to a Designating Party's

Protected Material designation is necessary to avoid foreseeable substantial unfairness,
unnecessary economic burdens, or a later significant disruption or delay of the litigation, a Party
does not waive its right to challenge a Protected Material designation by electing not to mount a
challenge promptly after the original designation is disclosed.

5.2

Meet and Confer.

A Party that elects to initiate a challenge to a

Designating Party's Protected Material designation must do so in good faith and must begin the
process by conferring directly (in voice to voice dialogue; other forms of communication are not
sufficient) with Outside Counsel for the Designating Party. In conferring, the challenging Party
must explain the basis for its belief that the Protected Material designation was not proper and
must give the Designating Party an opportunity to review the designated material, to reconsider
the circumstances, and, if no change in designation is offered, to explain the basis for the chosen
designation. A challenging Party may proceed to the next stage of the challenge process only if it
first has engaged in this meet and confer process and only after the Designating Party has been
given ten (10) calendar days to respond to the challenging Party's objection.
5.3

Judicial Intervention. A Party that elects to address a challenge to a

confidentiality designation after participating in the meet and confer required by Section 5.2 may
file and serve a motion that identifies the challenged material and sets forth in detail the basis for
the challenge or the designation. Absent good cause for extending the following deadlines, a
Party's motion must be filed within fourteen (14) days of (a) the Designating Party's response to
DOCSSV 1.433570.3

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9-

STIPULATED PROTECTIVE ORDER

the challenge or, if no response, (b) the expiration of the ten (10) days given to the Designating
Party to respond. Each such motion must be accompanied by a competent declaration that
affirms that the moving Party has complied with the meet and confer requirements imposed in
Section 5.2. The burden of persuasion in any such proceeding shall be on the Designating Party.
Until the court rules on the challenge, all parties shall continue to afford the material in question
the level of protection to which it is entitled under the Producing Party's designation.
6.

ACCESS TO AND USE OF PROTECTED MATERIAL
6.1

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

disclosed or produced by another Party or by a non-party in direct connection with this case or in
only for prosecuting, defending, or attempting to settle This Litigation. Protected Material may
be disclosed only to the categories of persons and under the conditions described in this Order.
When This Litigation (including all appeals) has been terminated, a Receiving Party must comply
with the provisions of Section 11 below. Protected Material must be stored and maintained by a
Receiving Party at a location and in a secure manner that ensures that access is limited to the
persons authorized under this Order.
6.2

Disclosure of "CONFIDENTIAL" Information or Items. Unless otherwise

ordered by the court or permitted in writing by the Designating Party, a Receiving Party may
disclose any information or item designated "Confidential" only to:
(a)

the Receiving Party's Outside Counsel of record in this action and its

employees directly involved with This Litigation;
(b)

the officers, directors, and employees (including In-House Counsel) of the

Receiving Party to whom disclosure is demonstrably necessary for This Litigation and who have
signed the "Agreement to Be Bound by Protective Order" (Exhibit A);
(c)

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

disclosure is demonstrably necessary for This Litigation and who have executed the "Agreement
to Be Bound by Protective Order" (Exhibit A);
(d)

the Court, its personnel, and any other person(s) designated by order of the

Court;
DOCSSV 1:433570 3

- loSTIPULATED PROTECTIVE ORDER

(e)

court reporters, their staffs, and Professional Vendors;

(f)

I

the author, recipients, and persons with prior knowledge of the document

or the original source of the information, who have not received such information in violation of
this Order or any confidentiality agreement; and
(g)

any person(s) jointly designated by the parties who have executed the

"Agreement to Be Bound by Protective Order" (Exhibit A).
6.3

Disclosure of "HIGHLY CONFIDENTIAL - ATTORNEYS' EYES

ONLY" Information or Items. Unless otherwise ordered by the court or permitted in writing by
the Designating Party, a Receiving Party may disclose any information or item designated
"Highly Confidential - Attorney's Eyes Only" only to:
(a)

Receiving Party's Outside Counsel of record in this action and its

(b)

Experts to whom disclosure is demonstrably necessary for This Litigation,

employees;

and who have signed the "Agreement to Be Bound by Protective Order" (Exhibit A);
(c)

the Court, its personnel and any other person(s) designated by order of the

(d)

court reporters, their staffs, and Professional Vendors;

(e)

any person(s) jointly designated by the parties who have executed the

Court;

"Agreement to Be Bound by Protective Order" (Exhibit A); and
(f)

the author of the document or the original source of the information.

6.4

Disclosure of Agreement to Be Bound By Protective Order (Exhibit A).

Counsel for the Party retaining the expert or consultant ("Retaining Party7') shall provide a copy
of the executed Exhibit A to the Designating Party.
6.5

Use of Confidential Material in Depositions. Whenever "Confidential" or

"Highly Confidential - Attorneys' Eyes Only" material is to be discussed or disclosed in a
deposition: (a) any person who has produced or will produce such material may require the
exclusion from the room of any person who is not entitled to receive such material under this
Order; and (b) any Party who will disclose material previously designated pursuant to Section 5,
DOCSSV 1r433570.3

1
I

- 11 STIPULATEDPROTECTIVE ORDER

above, shall first exclude from the room any person who is not entitled to receive such material
under this Order.
7.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

OTHER LITIGATION
If a Receiving Party is served with a subpoena or an order issued in other litigation that
would compel disclosure of any information or items designated in This Litigation as
"Confidential" or "Highly Confidential - Attorneys' Eyes Only," the Receiving Party must so
notify the Designating Party, in writing immediately and in no event more than three (3) court
days after receiving the subpoena or order. Such notification must include a copy of the subpoena
or court order.
The Receiving Party also must immediately inform in writing the party who caused the
subpoena or order to issue in the other litigation that some or all the material covered by the
subpoena or order is the subject of this Order. In addition, the Receiving Party must deliver a
copy of this Order promptly to the party in the other action that caused the subpoena or order to
issue.
The purpose of imposing these duties is to alert the interested parties to the existence of
this Order and to afford the Designating Party in This Litigation an opportunity to try to protect
its confidentiality interests in the court from which the subpoena or order issued. The
Designating Party shall bear the burdens and the expenses of seeking protection in that court of its
confidential material - and nothing in these provisions should be construed as authorizing or
encouraging a Receiving Party in This Litigation to disobey a lawful directive from another court.
8.

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 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 copies of the Protected Material, (c) inform the
person or persons to whom unauthorized disclosures were made of all the terms of this Order, and

(d) request such person or persons to execute the "Acknowledgment and Agreement to Be
DOCSSV1:433570.3
- 12STIPULATED PROTECTIVE ORDER

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

1 DATED: ~ e c e m b eJO,2005
r

ORRICK, HERRINGTON & SUTCLIFFE, LLP

By:
Attorneys for plaintiff' Facebook, Inc.
DATED: December ,

2005

FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, LLP

By:
Scott R. Mosko
Attorneys for Defendants ConnectU LLC, Cameron
Winklevoss, Tyler Winklevoss, Howard
Winklevoss, Divya Narendra

PURSUANT TO STIPULATION, IT IS SO ORDERED.

'JAN 182006

SOCRATES P. MOuKlAN

DATED:

. .

Hon. w#m%LE13wn.g
Judge of the Superior Court

DOCSSV 1 433570 3

-

15 -

S N " N ' T E D PROTECTNE ORDER

IT IS SO STIPULATED,THROUGH COUNSEL OF RECORD.

DATED: December

a,
2005

ORRICK, HERRINGTON & SUTCLTFFE, LLP

By:

Attorneys for plaintiff Facebook, Inc.
,
DATED: ~ e c e m b e r B2005

FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, LLP

By:
Attorneys for Defendants ConnectU LLC, Cameron
WinMevoss, Tyler Winklevoss, Howard
Winklevoss, Divya Narendra

PURSUANT TO STIPULATION, IT IS SO ORDERED.

DATED :
Hon. William J. Elfving
Judge of the Superior Court

WCSSV 1 :433570.3

- 15STIPULATED PROTECTIVE ORDER

EXHIBIT

EXHIBIT A
AGREEMENT TO BE BOUND BY PROTECTIVE ORDER
1,

, declare under penalty of perjury the following.

I have read in its entirety and understand the Stipulated Protective Order that was issued
by the Superior Court of the State of California, Santa Clara County on

-,

200-

in Case No. 1:05-CV-047381 currently pending in Superior Court of the State of California
between Facebook, Inc. and ConnectU LLC, Cameron Winklevoss, Tyler Winklevoss, Howard
Winklevoss, and Divya Narendra.
I have been provided with, carefully read, and understand the Stipulated Protective Order.
I will comply with and to be bound by all the terms of this Stipulated Protective Order. I
understand and acknowledge that failure to so comply could expose me to sanctions and
punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner
any confidential information or items that is subject to this Stipulated Protective Order prepared
or disclosed to me, including and abstracts, extracts, excerpts, and summaries thereof, to any
person or entity except in strict compliance with the provisions of this Order and will return said
confidential information or items in my possession to counsel for the party by whom I am
designated, employed, or retained.
I hereby submit to the jurisdiction of the Superior Court of State of California, Santa Clara
County for the purpose of enforcing the terms of this Stipulated Protective Order, even if such
enforcement proceedings occur after termination of this action.
[print or type full name] of

I hereby appoint

[print or type full address and
telephone number] as my California agent for service of process in connection with this action or
any proceedings related to enforcement of this Stipulated Protective Order.

. I am a citizen of the

My address is
United States.
My present employer is

My present occupation or job description is
DOCSSV1:433570 3

- 16STIPULATED PROTECTIVE ORDER

Date:
City and State where sworn and signed:
Printed name:

Signature:

DOCSSV 1:433570.3

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STIPULATED PROTECTNE ORDER