The opinion
mmaryott@gibsondunn.com
2 ASHLEY ALLYN, SBN 254559
aallyn@gibsondunn.com
3 GIBSON, DUNN & CRUTCHER LLP
3161 Michelson Drive
4 Irvine, CA 92612-4412
Telephone: 949.451.3800
5 Facsimile: 949.451.4220
JASON C. SCHWARTZ (admitted pro hac vice)
6
jschwartz@gibsondunn.com
GIBSON, DUNN & CRUTCHER LLP
7
1050 Connecticut Avenue, N.W.
Washington, DC 20036-5306
8
Telephone: 202.955.8500
Facsimile: 202.467.0539
9
KATHERINE V.A. SMITH, SBN 247866
10 ksmith@gibsondunn.com
HELEN AVUNJIAN, SBN 300284
11 havunjjian@gibsondunn.com
GIBSON, DUNN & CRUTCHER LLP
12 333 South Grand Avenue
Los Angeles, CA 90071-3197
13 Telephone: 213.229.7000
Facsimile: 213.229.7520
14
Attorneys for Defendants GOLDEN STATE FC LLC (now
known as AMAZON.COM SERVICES, INC.);
15
AMAZON.COM, INC.; and AMAZON FULFILLMENT
SERVICES, INC. (now known as AMAZON.COM
16
SERVICES, INC.)
17
[Additional Counsel Continued on Next Page]
18 UNITED STATES DISTRICT COURT
19 EASTERN DISTRICT OF CALIFORNIA
20 JUAN TREVINO, CHRISTOPHER WARD, Lead Case No. 1:18-cv-00120-DAD-BAM
LINDA QUINTEROS, ROMEO PALMA, Member Case No: 1:18-cv-00121-DAD-BAM
21 BRITTANY HAGMAN, ALBERTO
Member Case No: 1:18-cv-00567-DAD-BAM
GIANINI, and JUAN C. AVALOS, on behalf
22 of themselves and all others similarly situated, Member Case No: 1:18-cv-01176-DAD-BAM
Member Case No: 1:17-cv-01300-DAD-BAM
Plaintiffs,
23
v. STIPULATED PROTECTIVE ORDER
24 GOLDEN STATE FC LLC, a Delaware
Limited Liability Company; AMAZON.COM
25 INC., a Delaware Corporation, AMAZON
FULFILLMENT SERVICES, INC. a
26 Delaware Corporation, and Does 1 through 10,
inclusive,
27
Defendants.
28
peter@dion-kindemlaw.com
2 THE DION-KINDEM LAW FIRM
PETER R. DION-KINDEM, P.C.
3 2945 Townsgate Road, Suite 200
Westlake Village, CA 91361
4 Telephone: 818.883.4900
Facsimile: 858 404.9203
5
LONNIE C. BLANCHARD, III, SBN 93530
6 lonnieblanchard@gmail.com
THE BLANCHARD LAW GROUP, APC
7 3578 East Foothill Boulevard, Suite 338
Pasadena, CA 91107
8 Telephone: 213.599.8255
Facsimile: 213.402.3949
9
Attorneys for Plaintiff Juan Trevino
10
DAVID YEREMIAN, SBN 226337
david@yeremianlaw.com
11
ALVIN B. LINDSAY, SBN 220236
alvin@yeremianlaw.com
12
DAVID YEREMIAN & ASSOCIATES, INC.
535 North Brand Boulevard, Suite 705
13
Glendale, CA 91203-1989
Telephone: 818.230.8380
14
Facsimile: 818.230.0308
15 Attorneys for Plaintiffs Christopher Ward and
Linda Quinteros
16
JAMES HAWKINS, SBN 192925
17 james@jameshawkinsaplc.com
ISANDRA FERNANDEZ, SBN 220482
18 Isandra@jameshawkinsaplc.com
JAMES HAWKINS APLC
19 9880 Research Drive, Suite 200
Irvine, CA 92618
20 Telephone: 949.387.7200
Facsimile: 949.387.6676
21
Attorneys for Plaintiff Juan C. Avalos
22
JOSHUA H. HAFFNER, SBN 188652
jhh@haffnerlawyers.com
23
GRAHAM G. LAMBERT, SBN 303056
gl@haffnerlawyers.com
24
HAFFNER LAW PC
445 South Figueroa Street, Suite 2325
25
Los Angeles, CA 90071
Telephone: 213.514.5681
26
Facsimile: 213.514.5682
27 Attorneys for Plaintiff Romeo Palma
28
swestrick@westricklawfirm.com
2 THE WESTRICK LAW FIRM, P.C.
11075 Santa Monica Boulevard, Suite 125
3 Los Angeles, CA 90025
Telephone: 310.746.5303
4 Facsimile: 310.943.3373
Attorneys for Plaintiffs Brittany Hagman and
5
Alberto Gianini
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2 and Local Rule 141.1 of the Local Rules of the District Court for the Eastern District of California,
3 by and between Plaintiffs Juan Trevino, Christopher Ward, Linda Quinteros, Romeo Palma, Brittany
4 Hagman, Alberto Gianini, and Juan C. Avalos and Defendants Golden State FC LLC (now known as
5 Amazon.com Services, Inc.), Amazon.com Inc., and Amazon Fulfillment Services, Inc. (now known
6 as Amazon.com Services, Inc.) (“Defendants”) (collectively, the “Parties”), by and through their
7 respective undersigned counsel of record, that in order to facilitate the exchange of information and
8 documents which may be subject to confidentiality limitations on disclosure due to federal laws, state
9 laws, and privacy rights, the Parties respectfully request that the Court sign and enter the [Proposed]
10 Order following this Stipulated Protective Order to govern the production of documents and the
11 conduct of discovery in this action.
12 1. PURPOSES AND LIMITATIONS
13 Disclosure and discovery activity in this action are likely to involve production of
14 confidential, proprietary, or private information for which special protection from public disclosure
15 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly,
16 the Parties hereby stipulate to and petition the court to enter the following Stipulated Protective
17 Order. The Parties acknowledge that this Order does not confer blanket protections on all disclosures
18 or responses to discovery and that the protection it affords from public disclosure and use extends
19 only to the limited information or items that are entitled to confidential treatment under the applicable
20 legal principles. The Parties further acknowledge, as set forth in Section 12.3, below, that this
21 Stipulated Protective Order does not entitle them to file confidential information under seal; Local
22 Rule 141 sets forth the procedures that must be followed and the standards that will be applied when
23 a party seeks permission from the court to file material under seal.
24 2. DEFINITIONS
25 2.1 Challenging Party: a Party or Non-Party that challenges the designation of
26 information or items under this Order.
27
28
2 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of
3 Civil Procedure 26(c).
4 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well
5 as their support staff).
6 2.4 Designating Party: a Party or Non-Party that designates information or items that it
7 produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
8 2.5 Disclosure or Discovery Material: all items or information, regardless of the
9 medium or manner in which it is generated, stored, or maintained (including, among other things,
10 testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses
11 to discovery in this matter.
12 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to
13 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a
14 consultant in this action.
15 2.7 House Counsel: attorneys who are employees of a party to this action. House
16 Counsel does not include Outside Counsel of Record or any other outside counsel.
17 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal
18 entity not named as a Party to this action.
19 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this
20 action but are retained to represent or advise a party to this action and have appeared in this action on
21 behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.
22 2.10 Party: any party to this action, including all of its officers, directors, employees,
23 consultants, retained experts, and Outside Counsel of Record (and their support staffs).
24 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
25 Material in this action.
26 2.12 Professional Vendors: persons or entities that provide litigation support services
27 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing,
28 storing, or retrieving data in any form or medium) and their employees and subcontractors.
2 “CONFIDENTIAL.”
3 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a
4 Producing Party.
5 3. SCOPE
6 The protections conferred by this Stipulation and Order cover not only Protected Material (as
7 defined above), but also (1) any information copied or extracted from Protected Material; (2) all
8 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
9 conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
10 However, the protections conferred by this Stipulation and Order do not cover the following
11 information: (a) any information that is in the public domain at the time of disclosure to a Receiving
12 Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of
13 publication not involving a violation of this Order, including becoming part of the public record
14 through trial or otherwise; and (b) any information known to the Receiving Party prior to the
15 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the
16 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of
17 Protected Material at trial shall be governed by a separate agreement or order.
18 4. DURATION
19 Even after final disposition of this litigation, the confidentiality obligations imposed by this
20 Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order
21 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and
22 defenses in this action, with or without prejudice; and (2) final judgment herein after the completion
23 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the time
24 limits for filing any motions or applications for extension of time pursuant to applicable law.
25 5. DESIGNATING PROTECTED MATERIAL
26 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
27 Party or Non-Party that designates information or items for protection under this Order must take care
28 to limit any such designation to specific material that qualifies under the appropriate standards. The
2 oral or written communications that qualify. Mass, indiscriminate, or routinized designations are
3 prohibited.
4 If Designating Party learns that information or items that it designated for protection do not
5 qualify for protection, that Designating Party must promptly notify all other Parties that it is
6 withdrawing the mistaken designation.
7 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order
8 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
9 or Discovery Material that qualifies for protection under this Order must be clearly so designated
10 before the material is disclosed or produced.
11 Designation in conformity with this Order requires:
12 (a) for information in documentary form (e.g., paper or electronic documents, but
13 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party
14 affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a portion
15 or portions of the material on a page qualifies for protection, the Producing Party also must clearly
16 identify the protected portion(s) (e.g., by making appropriate markings in the margins).
17 A Party or Non-Party that makes original documents or materials available for inspection
18 need not designate them for protection until after the inspecting Party has indicated which material it
19 would like copied and produced. During the inspection and before the designation, all the material
20 made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
21 identified the documents it wants copied and produced, the Producing Party must determine which
22 documents, or portions thereof, qualify for protection under this Order. Then, before producing the
23 specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page
24 that contains Protected Material. If only a portion or portions of the material on a page qualifies for
25 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making
26 appropriate markings in the margins).
27 (b) for testimony given in deposition or in other pretrial or trial proceedings, that
28 the Designating Party shall either (1) identify on the record, before the close of the deposition,
2 “confidential” (before the proceedings is concluded) with the right to identify more specific portions
3 of the testimony as to which protection is sought within 30 days following receipt of the deposition
4 transcript.
5 (c) for information produced in some form other than documentary and for any
6 other tangible items, that the Producing Party shall affix in a prominent place on the exterior of the
7 container or containers in which the information or item is stored the legend “CONFIDENTIAL.” If
8 only a portion or portions of the information or item warrant protection, the Producing Party, to the
9 extent practicable, shall identify the protected portion(s).
10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
11 designate qualified information or items does not waive the Designating Party’s right to secure
12 protection under this Order for such material. Upon timely correction of a designation, the Receiving
13 Party must make reasonable efforts to assure that the material is treated in accordance with the
14 provisions of this Order. The Receiving Party shall also promptly destroy or return the inadvertently
15 produced material, and all copies thereof, and shall retain only the materials designated as
16 “confidential.”
17 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
18 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
19 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality
20 designation is necessary to avoid substantial unfairness, unnecessary economic burdens, or a
21 significant disruption or delay of the litigation, a Party does not waive its right to challenge a
22 confidentiality designation by electing not to mount a challenge promptly after the original
23 designation is disclosed.
24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process
25 by providing written notice of each designation it is challenging and describing the basis for each
26 challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must
27 recite that the challenge to confidentiality is being made in accordance with this specific paragraph of
28 the Protective Order. The Parties shall attempt to resolve each challenge in good faith and must begin
2 days of the date of service of notice. In conferring, the Challenging Party must explain the basis for
3 its belief that the confidentiality designation was not proper and must give the Designating Party an
4 opportunity to review the designated material, to reconsider the circumstances, and, if no change in
5 designation is offered, to explain the basis for the chosen designation. A Challenging Party may
6 proceed to the next stage of the challenge process only if it has engaged in this meet and confer
7 process first or establishes that the Designating Party is unwilling to participate in the meet and
8 confer process in a timely manner.
9 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court
10 intervention, the Designating Party shall file and serve a motion to retain confidentiality (and in
11 compliance with Local Rule 141, if applicable) within 30 calendar days of the initial notice of
12 challenge or within 21 calendar days of the Parties agreeing that the meet and confer process will not
13 resolve their dispute, whichever is later. Each such motion must be accompanied by a competent
14 declaration affirming that the movant has complied with the meet and confer requirements imposed
15 in the preceding paragraph. Failure by the Designating Party to make such a motion including the
16 required declaration within 30 calendar days (or 21 calendar days, if applicable) shall automatically
17 waive the confidentiality designation for each challenged designation. In addition, the Challenging
18 Party may file a motion challenging a confidentiality designation at any time if there is good cause
19 for doing so, including a challenge to the designation of a deposition transcript or any portions
20 thereof. Any motion brought pursuant to this provision must be accompanied by a competent
21 declaration affirming that the movant has complied with the meet and confer requirements imposed
22 by the preceding paragraph. The burden of persuasion in any such challenge proceeding shall be on
23 the Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass
24 or impose unnecessary expenses and burdens on other Parties) may expose the Challenging Party to
25 sanctions. Unless and until the Designating Party has waived the confidentiality designation by
26 failing to file a motion to retain confidentiality as described above, all Parties shall continue to afford
27 the material in question the level of protection to which it is entitled under the Producing Party’s
28 designation until the court rules on the challenge.
2 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or
3 produced by another Party or by a Non-Party in connection with this case only for prosecuting,
4 defending, or attempting to settle this litigation, and for no other purposes and no other client. Such
5 Protected Material may be disclosed only to the categories of persons and under the conditions
6 described in this Order. When the litigation has been terminated, a Receiving Party must comply with
7 the provisions of section 13 below (FINAL DISPOSITION).
8 Protected Material must be stored and maintained by a Receiving Party at a location and in a
9 secure manner that ensures that access is limited to the persons authorized under this Order.
10 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered
11 by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
12 information or item designated “CONFIDENTIAL” only to:
13 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as
14 employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the
15 information for this litigation and who have signed the “Acknowledgment and Agreement to Be
16 Bound” that is attached hereto as Exhibit A;
17 (b) the officers, directors, and employees (including House Counsel) of the
18 Receiving Party to whom disclosure is reasonably necessary for this litigation and who have signed
19 the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
20 (c) Experts (as defined in this Order) (i) to whom disclosure is reasonably
21 necessary for this litigation and (ii) who have signed the “Acknowledgment and Agreement to Be
22 Bound” (Exhibit A);
23 (d) the court and its personnel;
24 (e) court reporters and their staff, professional jury or trial consultants, mock
25 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this litigation and
26 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
27 (f) during their depositions, witnesses in the action to whom disclosure is
28 reasonably necessary and who have signed the “Acknowledgment and Agreement to Be Bound”
2 transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be
3 separately bound by the court reporter and may not be disclosed to anyone except as permitted under
4 this Stipulated Protective Order.
5 (g) the author or recipient of a document containing the information or a custodian
6 or other person who otherwise possessed or knew the information.
7 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
8 LITIGATION
9 If a Party is served with a subpoena or a court order issued in other litigation that compels
10 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party
11 must:
12 (a) promptly notify in writing the Designating Party. Such notification shall
13 include a copy of the subpoena or court order;
14 (b) promptly notify in writing the party who caused the subpoena or order to issue
15 in the other litigation that some or all of the material covered by the subpoena or order is subject to
16 this Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and
17 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
18 Designating Party whose Protected Material may be affected.
19 If the Designating Party timely seeks a protective order, the Party served with the subpoena or
20 court order shall not produce any information designated in this action as “CONFIDENTIAL” before
21 a determination by the court from which the subpoena or order issued, unless the Party has obtained
22 the Designating Party’s permission. The Designating Party shall bear the burden and expense of
23 seeking protection in that court of its confidential material – and nothing in these provisions should
24 be construed as authorizing or encouraging a Receiving Party in this action to disobey a lawful
25 directive from another court.
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2 THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced by a Non- Party
4 in this action and designated as “CONFIDENTIAL.” Such information produced by Non- Parties in
5 connection with this litigation is protected by the remedies and relief provided by this Order.
6 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional
7 protections.
8 (b) If a Party is required, by a valid discovery request, to produce a Non- Party’s
9 confidential information in its possession, and the Party is subject to an agreement with the Non-
10 Party not to produce the Non-Party’s confidential information, then the Party shall:
11 1) promptly notify in writing the Requesting Party and the Non-Party that
12 some or all of the information requested is subject to a confidentiality agreement with a Non- Party;
13 2) promptly provide the Non-Party with a copy of the Stipulated
14 Protective Order in this litigation, the relevant discovery request(s), and a reasonably specific
15 description of the information requested; and
16 3) make the information requested available for inspection by the Non-
17 Party.
18 (c) If the Non-Party fails to object or seek a protective order from this court within
19 14 days of receiving the notice and accompanying information, the Receiving Party may produce the
20 Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely
21 seeks a protective order, the Receiving Party shall not produce any information in its possession or
22 control that is subject to the confidentiality agreement with the Non-Party before a determination by
23 the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of
24 seeking protection in this court of its Protected Material.
25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
27 Material to any person or in any circumstance not authorized under this Stipulated Protective Order,
28 the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized
2 inform the person or persons to whom unauthorized disclosures were made of all the terms of this
3 Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to Be
4 Bound” that is attached hereto as Exhibit A.
5 11. PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL
6 The Parties specifically incorporate by reference the Stipulated Rule 502(d) Order
7 concurrently submitted to the Court.
8 12. MISCELLANEOUS
9 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to
10 seek its modification by the court in the future.
11 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective
12 Order no Party waives any right it otherwise would have to object to disclosing or producing any
13 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no
14 Party waives any right to object on any ground to use in evidence of any of the material covered by
15 this Protective Order.
16 12.3 Filing Protected Material. Without written permission from the Designating Party or
17 a court order secured after appropriate notice to all interested persons, a Party may not file in the
18 public record in this action any Protected Material. A Party that seeks to file under seal any Protected
19 Material must comply with Local Rule 141. Protected Material may only be filed under seal pursuant
20 to a court order authorizing the sealing of the specific Protected Material at issue. Pursuant to Local
21 Rule 141, a sealing order will issue only upon a request establishing that the Protected Material at
22 issue is privileged, protectable as a trade secret, or otherwise entitled to protection under the law. If a
23 Receiving Party's request to file Protected Material under seal pursuant to Local Rule is denied by the
24 court, then the Receiving Party may file the information in the public record pursuant to Local Rule
25 141 unless otherwise instructed by the court.
26 13. FINAL DISPOSITION
27 Within 60 days after the final disposition of this action, as defined in paragraph 4, each
28 Receiving Party must return all Protected Material to the Producing Party or destroy such material.
2 summaries, and any other format reproducing or capturing any of the Protected Material. Whether
3 the Protected Material is returned or destroyed, the Receiving Party must submit a written
4 certification to the Producing Party (and, if not the same person or entity, to the Designating Party) by
5 the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected Material that
6 was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies,
7 abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected
8 Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
9 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
10 correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant
11 and expert work product, even if such materials contain Protected Material. Any such archival copies
12 that contain or constitute Protected Material remain subject to this Protective Order as set forth in
13 Section 4 (for the duration of 1 year).
14 IT IS SO STIPULATED.
15
16 Dated: September 17, 2019
17 MICHELE L. MARYOTT
JASON C. SCHWARTZ
18 KATHERINE V.A. SMITH
ASHLEY ALLYN
19 HELEN AVUNJIAN
GIBSON, DUNN & CRUTCHER LLP
20
21 By: /s/ Katherine V.A. Smith
22 Attorneys for Defendants GOLDEN STATE FC LLC (now
known as AMAZON.COM SERVICES, INC.);
23 AMAZON.COM, INC.; and AMAZON FULFILLMENT
SERVICES, INC. (now known as AMAZON.COM
24 SERVICES, INC.)
25
26
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2 PETER R. DION-KINDEM
THE DION-KINDEM LAW FIRM
3
4 By: /s/ Peter R. Dion-Kindem as authorized on 9/17/19
5 LONNIE C. BLANCHARD, III
THE BLANCHARD LAW GROUP, APC
6
7 By: /s/ Lonnie C. Blanchard, III as authorized on 9/17/19
8 Attorneys for Plaintiff JUAN TREVINO
9 Dated: September 17, 2019
10 DAVID YEREMIAN
ALVIN B. LINDSAY
11 DAVID YEREMIAN & ASSOCIATES, INC.
12
By: /s/ Alvin B. Lindsay as authorized on 9/17/19
13
Attorneys for Plaintiffs CHRISTOPHER WARD and
14 LINDA QUINTEROS
15 Dated: September 17, 2019
16 JAMES HAWKINS
ISANDRA FERNANDEZ
17 JAMES HAWKINS APLC
18
By: /s/ Isandra Fernandez as authorized on 9/17/19
19
Attorneys for Plaintiff JUAN C. AVALOS
20
21 Dated: September 17, 2019
22 JOSHUA H. HAFFNER
GRAHAM G. LAMBERT
23 HAFFNER LAW PC
24
By: /s/ Joshua H. Haffner as authorized on 9/17/19
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Attorneys for Plaintiff ROMEO PALMA
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2 SHAWN C. WESTRICK
THE WESTRICK LAW FIRM, P.C.
3
4 By: /s/ Shawn C. Westrick as authorized on 9/17/19
5 Attorneys for Plaintiffs BRITTANY HAGMAN and
ALBERTO GIANINI
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2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _________________________________________ [print or type full name], of
4 __________________________________________ [print or type full address], declare under
5 penalty of perjury that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Eastern District of California on [date] in the
7 case of Juan Trevino v. Golden State FC LLC et al., Lead Case No. 18-cv-00120-DAD-BAM. I agree
8 to comply with and to be bound by all the terms of this Stipulated Protective Order and I understand
9 and acknowledge that failure to so comply could expose me to sanctions and punishment in the
10 nature of contempt. I solemnly promise that I will not disclose in any manner any information or item
11 that is subject to this Stipulated Protective Order to any person or entity except in strict compliance
12 with the provisions of this Order.
13 I further agree to submit to the jurisdiction of the United States District Court for the Eastern
14 District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even
15 if such enforcement proceedings occur after termination of this action.
16 I hereby appoint _____________________________________ [print or type full name] of
17 _________________________________________________________________ [print or type full
18 address and telephone number] as my California agent for service of process in connection with this
19 action or any proceedings related to enforcement of this Stipulated Protective Order.
20
21 Date:
22 City and State where sworn and signed:
23
24 Printed name:
25
26 Signature:
27
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2
The Court adopts the stipulated protective order submitted by the parties. The parties are advised that
3
pursuant to the Local Rules of the United States District Court, Eastern District of California, any
4
documents subject to this protective order to be filed under seal must be accompanied by a written
5
request which complies with Local Rule 141 prior to sealing. The party making a request to file
6
documents under seal shall be required to show good cause for documents attached to a non-
7
dispositive motion or compelling reasons for documents attached to a dispositive motion. Pintos v.
8
Pacific Creditors Ass’n, 605 F.3d 665, 677-78 (9th Cir. 2009). Within five (5) days of any approved
9
document filed under seal, the party shall file a redacted copy of the sealed document. The redactions
10
shall be narrowly tailored to protect only the information that is confidential or was deemed
11
confidential. Also, the parties shall consider resolving any dispute arising under this protective order
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according to the Court’s informal discovery dispute procedure.
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14 IT IS SO ORDERED.
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Dated: September 20, 2019 /s/ Barbara A. McAuliffe _
16 UNITED STATES MAGISTRATE JUDGE
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