# Jorge Perez v. Performance Food Group, Inc.

> District Court, C.D. California · November 14, 2019

URL: https://www.frixlaw.com/law-library/cases/10036105

## Case

- **Court:** District Court, C.D. California
- **Decided:** November 14, 2019
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1 SSEhaTuAn RSeEtHar eLhA, EWsq G. (RSBONU P20 4514) R M
2 Email: shaun@setarehlaw.com
Thomas Segal, Esq. (SBN 222791)
3 Email: thomas@setarehlaw.com
Farrah Grant, Esq. (SBN 293898)
4 Email: farrah@setarehlaw.com
315 S Beverly Drive, Suite 315
5 Beverly Hills, CA 90212
Tel: (310) 888-7771
6 Fax: (310) 888-0109

7 Attorneys for Plaintiff JORGE PEREZ

8
9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11
12 JORGE PEREZ, on behalf of CASE NO. 2:17-cv-00357-JAK-SK
himself, all others similarly situated,
13 and the general public, Assigned to: Hon. John A. Kronstadt

14 Plaintiffs, [Discovery Document: Referred to
Magistrate Judge Steve Kim]
15 vs.
STIPULATED PROTECTIVE
16 PERFORMANCE FOOD GROUP, ORDER
INC., a Colorado corporation;
17 VISTAR TRANSPORTATION,
LLC, a Delaware limited liability
18 company; ROMA FOOD
ENTERPRISES, INC., a California
19 corporation; and DOES 1-50,
inclusive,
20
Defendants.
21

22
23
24
25
26
27
28
1 1. GENERAL
2 1.1 Purposes and Limitations. Discovery in this action is likely to involve
3 production of confidential, proprietary, or private information for which special
4 protection from public disclosure and from use for any purpose other than
5 prosecuting this litigation may be warranted. Accordingly, the parties hereby
6 stipulate to and petition the Court to enter the following Stipulated Protective Order.
7 The parties acknowledge that this Order does not confer blanket protections on all
8 disclosures or responses to discovery and that the protection it affords from public
9 disclosure and use extends only to the limited information or items that are entitled
10 to confidential treatment under the applicable legal principles. The parties further
11 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order
12 does not entitle them to file confidential information under seal; Civil Local Rule 79-
13 5 sets forth the procedures that must be followed and the standards that will be
14 applied when a party seeks permission from the court to file material under seal.
15 1.2 Good Cause Statement. This action is likely to involve the disclosure
16 of (1) material protected under the constitutional, statutory, or common law right to
17 privacy and (2) confidential business, financial, proprietary, or private personnel,
18 policy, and payroll information for which special protection from public disclosure
19 and from use for any purpose other than prosecution of this action is warranted. Such
20 confidential and proprietary materials and information consist of, among other
21 things, confidential information regarding current and former employees;
22 confidential business or financial information; information regarding confidential
23 business practices; other confidential commercial information (including information
24 implicating privacy rights of third parties); information otherwise generally
25 unavailable to the public; and information that may be privileged or otherwise
26 protected from disclosure under state or federal statutes, court rules, case decisions,
27 or common law. Accordingly, to expedite the flow of information, to facilitate the
28 prompt resolution of disputes over confidentiality of discovery materials, to
1 adequately protect information the parties are entitled to keep confidential, to ensure
2 that the parties are permitted reasonable necessary uses of such material in
3 preparation for and in the conduct of trial, to address their handling at the end of the
4 litigation, and serve the ends of justice, a protective order for such information is
5 justified in this matter. It is the intent of the parties that information will not be
6 designated as confidential for tactical reasons and that nothing be so designated
7 without a good faith belief that it has been maintained in a confidential, non-public
8 manner, and there is good cause why it should not be part of the public record of this
9 case.
10 2. DEFINITIONS
11 2.1 Action: Action refers to the above-referenced matter titled Jorge Perez
12 v. Performance Food Group, Inc., et. Al.., Case No. 2:17-cv-00357-JAK-SK.
13 2.2 Challenging Party: a Party or Non-Party that challenges the designation
14 of information or items under this Order.
15 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
16 how it is generated, stored or maintained) or tangible things that have not been made
17 public or are not otherwise available or accessible in the public domain and that
18 qualify for protection under Federal Rule of Civil Procedure 26(c) or concern or
19 relate to the confidential or proprietary information of: (1) Defendants Performance
20 Food Group, Inc and Vistar Transportation, LLC.; (2) Plaintiffs; or (3) any third
21 parties, other than putative or certified class members, the disclosure of which
22 information is likely to have the effect of causing harm to the competitive position of
23 Defendant or to the organization or person from whom the information was obtained
24 or to the party’s privacy. Information designated Confidential may be used only in
25 connection with this proceeding and not for any other purpose. Such information
26 may not be disclosed to anyone except as provided in this Order.
27 2.4 Counsel: “Counsel” means Outside Counsel of Record and House
28 Counsel (as well as their support staff), including, but not limited to:
1 1) Setareh Law Group and its support staff and other employees who
2 are not employed by a Party and to whom it is necessary to
3 disclose Confidential Information for the purpose of this action;
4 2) McGuireWoods LLP and its support staff and other employees
5 who are not employed by a Party and to whom it is necessary to
6 disclose Confidential Information for the purpose of this action;
7 2.5 Designating Party: a Party or Non-Party that designates information or
8 items that it produces in disclosures or in responses to discovery as
9 “CONFIDENTIAL.”
10 2.6 Disclosure or Discovery Material: all items or information, regardless
11 of the medium or manner in which it is generated, stored, or maintained (including,
12 among other things, testimony, transcripts, and tangible things), that are produced or
13 generated in disclosures or responses to discovery in this matter, or in connection
14 with any settlement administration.
15 2.7 Expert: a person with specialized knowledge or experience in a matter
16 pertinent to the litigation who has been retained by a Party or its counsel to serve as
17 an expert witness or as a consultant in this Action.
18 2.8 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
19 Information or Items: extremely sensitive “Confidential Information or Items,”
20 disclosure of which to another Party or Non-Party would create a substantial risk of
21 serious harm that could not be avoided by less restrictive means. Highly Confidential
22 – Attorneys’ Eyes-Only Information includes private information pertaining to
23 putative or certified class members, for which Defendant or a third party has a duty
24 to maintain the confidentiality of such information, including any such information
25 that may be required to be provided to any settlement administrator. Information
26 designated Highly Confidential – Attorneys’ Eyes Only (referred to herein as an
27 “AEO” designation) may be used only in connection with this proceeding and not for
28
1 any other purpose. Such information may not be disclosed to anyone except as
2 provided in this Order.
3 2.9 House Counsel: attorneys who are employees of a party to this Action.
4 House Counsel does not include Outside Counsel of Record or any other outside
5 counsel.
6 2.10 Non-Party: any natural person, partnership, corporation, association, or
7 other legal entity not named as a Party to this action.
8 2.11 Outside Counsel of Record: attorneys who are not employees of a party
9 to this Action but are retained to represent or advise a party to this Action and have
10 appeared in this Action on behalf of that party or are affiliated with a law firm that
11 has appeared on behalf of that party, including support staff.
12 2.12 Party: any party to this Action, including all of its officers, directors,
13 employees, consultants, retained experts, Professional Vendors, and Counsel (and
14 their support staffs).
15 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
16 Discovery Material in this Action.
17 2.14 Professional Vendors: persons or entities that provide litigation support
18 services (e.g., photocopying, videotaping, translating, preparing exhibits or
19 demonstrations, and organizing, storing, or retrieving data in any form or medium)
20 and their employees and subcontractors, including settlement administrators.
21 2.15 Protected Material: any Disclosure or Discovery Material that is
22 designated as “CONFIDENTIAL” or “AEO.”
23 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material
24 from a Producing Party.
25 3. SCOPE
26 The protections conferred by this Stipulation and Order cover not only
27 Protected Material (as defined above), but also (1) any information copied or
28 extracted from Protected Material; (2) all copies, excerpts, summaries, or
1 compilations of Protected Material; and (3) any testimony, conversations, or
2 presentations by Parties or their Counsel that might reveal Protected Material.
3 Any use of Protected Material at trial shall be governed by the orders of the
4 trial judge. This Order does not govern the use of Protected Material at trial.
5 4. DURATION
6 Once a case proceeds to trial, all of the court-filed information to be introduced
7 that was previously designated as confidential or maintained pursuant to this
8 protective order becomes public and will be presumptively available to all members
9 of the public, including the press, unless compelling reasons supported by specific
10 factual findings to proceed otherwise are made to the trial judge in advance of the
11 trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th
12 Cir. 2006) (distinguishing “good cause” showing for sealing documents produced in
13 discovery from “compelling reasons” standard when merits-related documents are
14 part of court record). Accordingly, the terms of this protective order do not extend
15 beyond the commencement of the trial.
16 5. DESIGNATING PROTECTED MATERIAL
17 5.1 Exercise of Restraint and Care in Designating Material for Protection.
18 Each Party or Non-Party that designates information or items for protection under
19 this Order must take care to limit any such designation to specific material that
20 qualifies under the appropriate standards. The Designating Party must designate for
21 protection only those parts of material, documents, items, or oral or written
22 communications that qualify so that other portions of the material, documents, items,
23 or communications for which protection is not warranted are not swept unjustifiably
24 within the ambit of this Order.
25 Mass, indiscriminate, or routinized designations are prohibited. Designations
26 that are shown to be clearly unjustified or that have been made for an improper
27 purpose (e.g., to unnecessarily encumber the case development process or to impose
28 unnecessary expenses and burdens on other parties) may expose the Designating
1 Party to sanctions.
2 If it comes to a Designating Party’s attention that information or items that it
3 designated for protection do not qualify for protection, that Designating Party must
4 promptly notify all other Parties that it is withdrawing the inapplicable designation.
5 5.2 Manner and Timing of Designations. Except as otherwise provided in
6 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
7 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
8 under this Order must be clearly so designated before the material is disclosed or
9 produced.
10 Designation in conformity with this Order requires:
11 (a) for information in documentary form (e.g., paper or electronic
12 documents, but excluding transcripts of depositions or other pretrial or trial
13 proceedings), that the Producing Party affix, at a minimum, the legend
14 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
15 ONLY” (hereinafter referred to collectively as a “CONFIDENTIAL legend”), to
16 each page that contains protected material. If only a portion or portions of the material
17 on a page qualifies for protection, the Producing Party also must clearly identify the
18 protected portion(s) (e.g., by making appropriate markings in the margins).
19 A Party or Non-Party that makes original documents available for inspection
20 need not designate them for protection until after the inspecting Party has indicated
21 which documents it would like copied and produced. During the inspection and
22 before the designation, all of the material made available for inspection shall be
23 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
24 it wants copied and produced, the Producing Party must determine which documents,
25 or portions thereof, qualify for protection under this Order. Then, before producing
26 the specified documents, the Producing Party must affix the “CONFIDENTIAL
27 legend” to each page that contains Protected Material. If only a portion or portions
28 of the material on a page qualifies for protection, the Producing Party also must
1 clearly identify the protected portion(s) (e.g., by making appropriate markings in the
2 margins).
3 (b) for testimony given in depositions that the Designating Party
4 identify the Disclosure or Discovery Material on the record, before the close of the
5 deposition.
6 (c) for information produced in some form other than documentary
7 and for any other tangible items, that the Producing Party affix in a prominent place
8 on the exterior of the container or containers in which the information is stored the
9 legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
10 EYES ONLY.” If only a portion or portions of the information warrants protection,
11 the Producing Party, to the extent practicable, shall identify the protected portion(s).
12 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
13 failure to designate qualified information or items does not, standing alone, waive
14 the Designating Party’s right to secure protection under this Order for such material.
15 Upon timely correction of a designation, the Receiving Party must make reasonable
16 efforts to assure that the material is treated in accordance with the provisions of this
17 Order.
18 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
19 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
20 designation of confidentiality at any time that is consistent with the Court’s
21 Scheduling Order.
22 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
23 resolution process under Local Rule 37.1, et seq. Any discovery motion must strictly
24 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
25 6.3 Burden. The burden of persuasion in any such challenge proceeding
26 shall be on the Designating Party. Frivolous challenges, and those made for an
27 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
28 other parties) may expose the Challenging Party to sanctions. Unless the Designating
1 Party has waived or withdrawn the confidentiality designation, all parties shall
2 continue to afford the material in question the level of protection to which it is entitled
3 under the Producing Party’s designation until the Court rules on the challenge.
4 7. ACCESS TO AND USE OF PROTECTED MATERIAL
5 7.1 Basic Principles. A Receiving Party may use Protected Material that is
6 disclosed or produced by another Party or by a Non-Party in connection with this
7 Action only for prosecuting, defending, or attempting to settle this Action. Such
8 Protected Material may be disclosed only to the categories of persons and under the
9 conditions described in this Order. When the Action has been terminated, a Receiving
10 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
11 Protected Material must be stored and maintained by a Receiving Party at a
12 location and in a secure manner that ensures that access is limited to the persons
13 authorized under this Order.
14 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
15 otherwise ordered by the Court or permitted in writing by the Designating Party, a
16 Receiving Party may disclose any information or item designated
17 “CONFIDENTIAL” only to:
18 (a) the Receiving Party’s Outside Counsel of Record in this Action,
19 as well as employees of said Outside Counsel of Record to whom it is reasonably
20 necessary to disclose the information for this Action;
21 (b) the officers, directors, and employees (including House Counsel)
22 of the Receiving Party to whom disclosure is reasonably necessary for this Action;
23 (c) Experts (as defined in this Order) of the Receiving Party to whom
24 disclosure is reasonably necessary for this Action and who have signed the
25 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
26 (d) the Court and its personnel;
27 (e) court reporters and their staff;
28
1 (f) professional jury or trial consultants, mock jurors, and
2 Professional Vendors to whom disclosure is reasonably necessary for this Action and
3 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (g) the author or recipient of a document containing the information
5 or a custodian or other person who otherwise possessed or knew the information;
6 (h) during their depositions, witnesses, and attorneys for witnesses,
7 in the Action to whom disclosure is reasonably necessary provided: (1) the deposing
8 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
9 they will not be permitted to keep any confidential information unless they sign the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
11 agreed by the Designating Party or ordered by the Court. Pages of transcribed
12 deposition testimony or exhibits to depositions that reveal Protected Material may be
13 separately bound by the court reporter and may not be disclosed to anyone except as
14 permitted under this Stipulated Protective Order; and
15 (i) any mediator or settlement officer, and their supporting
16 personnel, mutually agreed upon by any of the parties engaged in settlement
17 discussions.
18 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
19 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in
20 writing by the Designating Party, a Receiving Party may disclose any information or
21 item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only
22 to:
23 (a) the Receiving Party’s Counsel, as well as employees of said
24 Counsel to whom it is reasonably necessary to disclose the information for this
25 litigation and who have signed the “Acknowledgment and Agreement to Be Bound”
26 that is attached hereto as Exhibit A;
27 (b) Experts of the Receiving Party (1) to whom disclosure is
28 reasonably necessary for this litigation, and (2) who have signed the
1 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
2 (c) the Court and its personnel;
3 (d) court reporters and their staff, professional jury or trial
4 consultants, and Professional Vendors to whom disclosure is reasonably necessary
5 for this litigation and who have signed the “Acknowledgment and Agreement to Be
6 Bound” (Exhibit A);
7 (e) during their depositions, witnesses in the action to whom
8 disclosure is reasonably necessary and who have signed the “Acknowledgment and
9 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating
10 Party or ordered by the Court. Pages of transcribed deposition testimony or exhibits
11 to depositions that reveal Protected Material must be separately bound by the court
12 reporter and may not be disclosed to anyone except as permitted under this Protective
13 Order; and
14 (f) the author or recipient of a document containing the information
15 or a custodian or other person who otherwise possessed or knew the information;
16 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
17 PRODUCED IN OTHER LITIGATION
18 If a Party is served with a subpoena or a court order issued in other litigation
19 that compels disclosure of any information or items designated in this Action as
20 “CONFIDENTIAL” or “AEO,” that Party must:
21 (a) promptly notify in writing the Designating Party. Such
22 notification shall include a copy of the subpoena or court order;
23 (b) promptly notify in writing the party who caused the subpoena or
24 order to issue in the other litigation that some or all of the material covered by the
25 subpoena or order is subject to this Protective Order. Such notification shall include
26 a copy of this Stipulated Protective Order; and
27 (c) cooperate with respect to all reasonable procedures sought to be
28 pursued by the Designating Party whose Protected Material may be affected.
1 If the Designating Party timely seeks a protective order, the Party served with
2 the subpoena or court order shall not produce any information designated in this
3 action as “CONFIDENTIAL” or “AEO” before a determination by the court from
4 which the subpoena or order issued, unless the Party has obtained the Designating
5 Party’s permission. The Designating Party shall bear the burden and expense of
6 seeking protection in that court of its confidential material and nothing in these
7 provisions should be construed as authorizing or encouraging a Receiving Party in
8 this Action to disobey a lawful directive from another court.
9 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
10 PRODUCED IN THIS LITIGATION
11 (a) The terms of this Order are applicable to information produced by a
12 Non-Party in this Action and designated as “CONFIDENTIAL” or “AEO.” Such
13 information produced by Non-Parties in connection with this litigation is protected
14 by the remedies and relief provided by this Order. Nothing in these provisions should
15 be construed as prohibiting a Non-Party from seeking additional protections.
16 (b) In the event that a Party is required, by a valid discovery request, to
17 produce a Non-Party’s confidential information in its possession, and the Party is
18 subject to an agreement with the Non-Party not to produce the Non-Party’s
19 confidential information, then the Party shall:
20 (1) promptly notify in writing the Requesting Party and the Non-
21 Party that some or all of the information requested is subject to a confidentiality
22 agreement with a Non-Party;
23 (2) promptly provide the Non-Party with a copy of the Stipulated
24 Protective Order in this Action, the relevant discovery request(s), and a reasonably
25 specific description of the information requested; and
26 (3) make the information requested available for inspection by the
27 Non-Party, if requested.
28
1 (c) If the Non-Party fails to seek a protective order from this Court within
2 14 days of receiving the notice and accompanying information, the Receiving Party
3 may produce the Non-Party’s confidential information responsive to the discovery
4 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
5 not produce any information in its possession or control that is subject to the
6 confidentiality agreement with the Non-Party before a determination by the Court.
7 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
8 of seeking protection in this Court of its Protected Material.
9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
11 Protected Material to any person or in any circumstance not authorized under this
12 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
13 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
14 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
15 persons to whom unauthorized disclosures were made of all the terms of this Order,
16 and (d) request such person or persons to execute the “Acknowledgment and
17 Agreement to Be Bound” that is attached hereto as Exhibit A.
18 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
19 PROTECTED MATERIAL
20 When a Producing Party gives notice to Receiving Parties that certain
21 inadvertently produced material is subject to a claim of privilege or other protection,
22 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
23 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
24 may be established in an e-discovery order that provides for production without prior
25 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
26 parties reach an agreement on the effect of disclosure of a communication or
27 information covered by the attorney-client privilege or work product protection, the
28 parties may incorporate their agreement in the stipulated protective order submitted
1 to the Court.
2 12. MISCELLANEOUS
3 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
4 person to seek its modification by the Court in the future.
5 12.2 Right to Assert Other Objections. By stipulating to the entry of this
6 Protective Order, no Party waives any right it otherwise would have to object to
7 disclosing or producing any information or item on any ground not addressed in this
8 Stipulated Protective Order. Similarly, no Party waives any right to object on any
9 ground to use in evidence of any of the material covered by this Protective Order.
10 12.3 Filing Protected Material. A Party that seeks to file under seal any
11 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
12 only be filed under seal pursuant to a court order authorizing the sealing of the
13 specific Protected Material at issue; good cause must be shown in the request to file
14 under seal. If a Party’s request to file Protected Material under seal is denied by the
15 Court, then the Receiving Party may file the information in the public record unless
16 otherwise instructed by the Court.
17 13. FINAL DISPOSITION
18 After the final disposition of this Action, within 60 days of a written request
19 by the Designating Party, each Receiving Party must return all Protected Material to
20 the Producing Party or destroy such material. As used in this subdivision, “all
21 Protected Material” includes all copies, abstracts, compilations, summaries, and any
22 other format reproducing or capturing any of the Protected Material. Whether the
23 Protected Material is returned or destroyed, the Receiving Party must submit a
24 written certification to the Producing Party (and, if not the same person or entity, to
25 the Designating Party) by the 60 day deadline that (1) identifies (by category, where
26 appropriate) all the Protected Material that was returned or destroyed and (2) affirms
27 that the Receiving Party has not retained any copies, abstracts, compilations,
28 summaries or any other format reproducing or capturing any of the Protected
1 | Material. Notwithstanding this provision, counsel are entitled to retain an archival
2 | copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
3 | memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
4 | work product, and consultant and expert work product, even if such materials contain
5 | Protected Material. Any such archival copies that contain or constitute Protected
6 | Material remain subject to this Protective Order as set forth in Section 4
7 | (DURATION).
8 | 14. VIOLATION OF ORDER
9 Any violation of this Order may be punished by any and all appropriate
10 | measures including, without limitation, contempt proceedings and/or monetary
11 | sanctions.
12 | ITISSO STIPULATED, THROUGH COUNSEL OF RECORD.
13
14 | Dated: July 23, 2019 /s/
Shaun Setareh
IS Setareh Law Group.
Attorneys for Plaintiff
16 Jorge Perez
17
Dated: July 23, 2019 /s/
18 Matthew C. Kane
McGUIREWoops LLP
19 Attorneys for Defendants
Performance Food Group, Inc. and
20 Vistar Transportation, LLC
21
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
22

DATED: _ November 14, 2019
24 Honorable Steve Kim
United States Magistrate Judge
26
27
28
-14-

1 Exhibit A

2
UNITED STATES DISTRICT COURT
3 CENTRAL DISTRICT OF CALIFORNIA
4
5 JORGE PEREZ, on behalf of himself, all Case No. 2:17-cv-00357-JAK-SK
others similarly situated, and the general
6 public, AGREEMENT TO BE BOUND BY
PROTECTIVE ORDER
7
Plaintiffs,
8 vs.

9
PERFORMANCE FOOD GROUP, INC.,
a Colorado corporation; VISTAR
10
TRANSPORTATION, LLC, a Delaware
limited liability company; ROMA FOOD
11
ENTERPRISES, INC., a California
corporation; and DOES 1-50, inclusive,
12
13 Defendants.
14
15
The undersigned hereby acknowledges that he/she having read the
16
Stipulated Protective Order entered in the above-captioned action and attached
17
hereto, understands the terms thereof and agrees to be bound by its terms, ensuring
18
that any employees and/or clerical assistants will also abide thereby. The
19
undersigned submits to the jurisdiction of this Court in matters relating to the
20
Protective Order and understands that the terms obligate him/her to use documents
21
designated “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
22
23 EYES ONLY” in accordance with the Protective Order solely for the purposes of
24 the above-captioned action, and not to disclose any such documents or information
25 derived directly therefrom to any other person, firm, or concern.
26
27
28
1 The undersigned acknowledges that violation of the Protective Order
2 may result in penalties for contempt of court.
3
4 Entered into on this _________ day of ______________________,
5 ____.
6
7
8
Signature: ________________________________
9
Print Name: ________________________________
10
11 Address: ________________________________
12
________________________________
13
14
15
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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10036105. Public record. Not legal advice.