# Anthony Longo v. Vincent Longo

> District Court, C.D. California · November 25, 2020

URL: https://www.frixlaw.com/law-library/cases/10039585

## Case

- **Court:** District Court, C.D. California
- **Decided:** November 25, 2020
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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ANTHONY LONGO, individually Case No. SA 20-cv-00829-AB-RAO
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and derivatively on behalf of TODOS
12 SANTOS SURF, INC., STIPULATED PROTECTIVE
ORDER1
13 v.

14 VINCENT LONGO, an individual;
FUTURE FIN SYSTEMS PTY LTD,
15 an Australian entity; and DOES 1
through 20, inclusive;
16
Defendants
17
-and-
18 TODOS SANTOS SURF, INC., a
19 California Corporation,
Nominal Defendant
20

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1. A. PURPOSES AND LIMITATIONS
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Discovery in this action is likely to involve production of confidential,
24
proprietary or private information for which special protection from public
25
disclosure and from use for any purpose other than prosecuting this litigation may
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1 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
2 enter the following Stipulated Protective Order. The parties acknowledge that this
3 Order does not confer blanket protections on all disclosures or responses to
4 discovery and that the protection it affords from public disclosure and use extends
5 only to the limited information or items that are entitled to confidential treatment
6 under the applicable legal principles.
7
8 B. GOOD CAUSE STATEMENT
9 This action is likely to involve trade secrets, customer and pricing lists and
10 other valuable research, development, commercial, financial, technical and/or
11 proprietary information for which special protection from public disclosure and
12 from use for any purpose other than prosecution of this action is warranted. Such
13 confidential and proprietary materials and information consist of, among other
14 things, confidential business or financial information, information regarding
15 confidential business practices, or other confidential research, development, or
16 commercial information (including information implicating privacy rights of third
17 parties), information otherwise generally unavailable to the public, or which may be
18 privileged or otherwise protected from disclosure under state or federal statutes,
19 court rules, case decisions, or common law. Accordingly, to expedite the flow of
20 information, to facilitate the prompt resolution of disputes over confidentiality of
21 discovery materials, to adequately protect information the parties are entitled to keep
22 confidential, to ensure that the parties are permitted reasonable necessary uses of
23 such material in preparation for and in the conduct of trial, to address their handling
24 at the end of the litigation, and serve the ends of justice, a protective order for such
25 information is justified in this matter. It is the intent of the parties that information
26 will not be designated as confidential for tactical reasons and that nothing be so
27 designated without a good faith belief that it has been maintained in a confidential,
1 non-public manner, and there is good cause why it should not be part of the public
2 record of this case.
3
4 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
5 The parties further acknowledge, as set forth in Section 12.3, below, that this
6 Stipulated Protective Order does not entitle them to file confidential information
7 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
8 and the standards that will be applied when a party seeks permission from the court
9 to file material under seal.
10 There is a strong presumption that the public has a right of access to judicial
11 proceedings and records in civil cases. In connection with non-dispositive motions,
12 good cause must be shown to support a filing under seal. See Kamakana v. City and
13 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
14 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics,
15 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
16 require good cause showing), and a specific showing of good cause or compelling
17 reasons with proper evidentiary support and legal justification, must be made with
18 respect to Protected Material that a party seeks to file under seal. The parties’ mere
19 designation of Disclosure or Discovery Material as CONFIDENTIAL or HIGHLY
20 CONFIDENTIAL – ATTORNEYS’ EYES ONLY does not—without the
21 submission of competent evidence by declaration, establishing that the material
22 sought to be filed under seal qualifies as confidential, privileged, or otherwise
23 protectable—constitute good cause.
24 Further, if a party requests sealing related to a dispositive motion or trial, then
25 compelling reasons, not only good cause, for the sealing must be shown, and the
26 relief sought shall be narrowly tailored to serve the specific interest to be protected.
27 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For
1 under seal in connection with a dispositive motion or trial, the party seeking
2 protection must articulate compelling reasons, supported by specific facts and legal
3 justification, for the requested sealing order. Again, competent evidence supporting
4 the application to file documents under seal must be provided by declaration.
5 Any document that is not confidential, privileged, or otherwise protectable in
6 its entirety will not be filed under seal if the confidential portions can be redacted.
7 If documents can be redacted, then a redacted version for public viewing, omitting
8 only the confidential, privileged, or otherwise protectable portions of the document
9 shall be filed. Any application that seeks to file documents under seal in their
10 entirety should include an explanation of why redaction is not feasible.
11
12 2. DEFINITIONS
13 2.1 Action: Anthony Longo v. Vincent Longo; Future Fin Systems Pty Ltd,
14 Case No. 20-cv-00829-AB-RAO.
15 2.2 Challenging Party: a Party or Non-Party that challenges the
16 designation of information or items under this Order.
17 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
18 how it is generated, stored or maintained) or tangible things that qualify for
19 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
20 the Good Cause Statement.
21 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
22 their support staff).
23 2.5 Designating Party: a Party or Non-Party that designates information or
24 items that it produces in disclosures or in responses to discovery as
25 “CONFIDENTIAL.”
26 2.6 Disclosure or Discovery Material: all items or information, regardless
27 of the medium or manner in which it is generated, stored, or maintained (including,
1 generated in disclosures or responses to discovery in this matter.
2 2.7 Expert: a person with specialized knowledge or experience in a matter
3 pertinent to the litigation who has been retained by a Party or its counsel to serve as
4 an expert witness or as a consultant in this Action.
5 2.8 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
6 Information or Items: extremely sensitive confidential, or proprietary information or
7 tangible things, such as technical know-how and trade secrets, relating to: (1)
8 information relating to manufacturing processes or procedures with respect to
9 devices or other products that are commercially released or for which substantial
10 steps have been taken towards commercialization; or (2) information generated by
11 research and development activities.; or (3) information that otherwise derives
12 independent economic value, actual or potential, from not being generally known to
13 the public or to other persons who can obtain economic value from its disclosure or
14 use. The disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
15 ONLY” to another Party or Non-Party would create a substantial risk of serious
16 harm that could not be avoided by less restrictive means.
17 2.9 House Counsel: attorneys who are employees of a party to this Action.
18 House Counsel does not include Outside Counsel of Record or any other outside
19 counsel.
20 2.10 Non-Party: any natural person, partnership, corporation, association or
21 other legal entity not named as a Party to this action.
22 2.11 Outside Counsel of Record: attorneys who are not employees of a
23 party to this Action but are retained to represent or advise a party to this Action and
24 have appeared in this Action on behalf of that party or are affiliated with a law firm
25 that has appeared on behalf of that party, and includes support staff.
26 2.12 Party: any party to this Action, including all of its officers, directors,
27 employees, consultants, retained experts, and Outside Counsel of Record (and their
1 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
2 Discovery Material in this Action.
3 2.14 Professional Vendors: persons or entities that provide litigation
4 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
5 demonstrations, and organizing, storing, or retrieving data in any form or medium)
6 and their employees and subcontractors.
7 2.15 Protected Material: any Disclosure or Discovery Material that is
8 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -
9 ATTORNEYS’ EYES ONLY.”
10 2.16 Receiving Party: a Party that receives Disclosure or Discovery
11 Material from a Producing Party.
12
13 3. SCOPE
14 The protections conferred by this Stipulation and Order cover not only
15 Protected Material (as defined above), but also (1) any information copied or
16 extracted from Protected Material; (2) all copies, excerpts, summaries, or
17 compilations of Protected Material; and (3) any testimony, conversations, or
18 presentations by Parties or their Counsel that might reveal Protected Material.
19 Any use of Protected Material at trial shall be governed by the orders of the
20 trial judge. This Order does not govern the use of Protected Material at trial.
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22 4. DURATION
23 Once a case proceeds to trial, information that was designated as
24 CONFIDENTIAL and/or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
25 ONLY or maintained pursuant to this protective order used or introduced as an
26 exhibit at trial becomes public and will be presumptively available to all members of
27 the public, including the press, unless compelling reasons supported by specific
1 trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for
2 sealing documents produced in discovery from “compelling reasons” standard when
3 merits-related documents are part of court record). Accordingly, the terms of this
4 protective order do not extend beyond the commencement of the trial.
5
6 5. DESIGNATING PROTECTED MATERIAL
7 5.1 Exercise of Restraint and Care in Designating Material for Protection.
8 Each Party or Non-Party that designates information or items for protection under
9 this Order must take care to limit any such designation to specific material that
10 qualifies under the appropriate standards. The Designating Party must designate for
11 protection only those parts of material, documents, items or oral or written
12 communications that qualify so that other portions of the material, documents, items
13 or communications for which protection is not warranted are not swept unjustifiably
14 within the ambit of this Order.
15 Mass, indiscriminate or routinized designations are prohibited. Designations
16 that are shown to be clearly unjustified or that have been made for an improper
17 purpose (e.g., to unnecessarily encumber the case development process or to impose
18 unnecessary expenses and burdens on other parties) may expose the Designating
19 Party to sanctions.
20 If it comes to a Designating Party’s attention that information or items that it
21 designated for protection do not qualify for protection, that Designating Party must
22 promptly notify all other Parties that it is withdrawing the inapplicable designation.
23 5.2 Manner and Timing of Designations. Except as otherwise provided in
24 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
26 under this Order must be clearly so designated before the material is disclosed or
27 produced.
1 (a) for information in documentary form (e.g., paper or electronic
2 documents, but excluding transcripts of depositions or other pretrial or trial
3 proceedings), that the Producing Party affix at a minimum, the legend
4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) or the legend
5 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” (hereinafter
6 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY legend”), to each
7 page that contains protected material. If only a portion of the material on a page
8 qualifies for protection, the Producing Party also must clearly identify the protected
9 portion(s) (e.g., by making appropriate markings in the margins).
10 A Party or Non-Party that makes original documents available for inspection
11 need not designate them for protection until after the inspecting Party has indicated
12 which documents it would like copied and produced. During the inspection and
13 before the designation, all of the material made available for inspection shall be
14 deemed “ATTORNEYS’ EYES ONLY.” After the inspecting Party has identified
15 the documents it wants copied and produced, the Producing Party must determine
16 which documents, or portions thereof, qualify for protection under this Order. Then,
17 before producing the specified documents, the Producing Party must affix the
18 “CONFIDENTIAL legend” and/or the “HIGHLY CONFIDENTIAL –
19 ATTORNEYS’ EYES ONLY” legend, as appropriate, to each page that contains
20 Protected Material. If only a portion of the material on a page qualifies for
21 protection, the Producing Party also must clearly identify the protected portion(s)
22 (e.g., by making appropriate markings in the margins).
23 (b) for testimony given in depositions that the Designating Party identifies
24 the Disclosure or Discovery Material on the record, before the close of the
25 deposition all protected testimony.
26 (c) for information produced in some form other than documentary and
27 for any other tangible items, that the Producing Party affix in a prominent place on
1 “CONFIDENTIAL” legend and/or the “HIGHLY CONFIDENTIAL –
2 ATTORNEYS’ EYES ONLY” legend, as appropriate. If only a portion or portions
3 of the information warrants protection, the Producing Party, to the extent
4 practicable, shall identify the protected portion(s).
5 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
6 failure to designate qualified information or items does not, standing alone, waive
7 the Designating Party’s right to secure protection under this Order for such material.
8 Upon timely correction of a designation, the Receiving Party must make reasonable
9 efforts to assure that the material is treated in accordance with the provisions of this
10 Order.
11
12 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
13 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
14 designation of confidentiality at any time that is consistent with the Court’s
15 Scheduling Order.
16 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
17 resolution process under Local Rule 37.1 et seq.
18 6.3 The burden of persuasion in any such challenge proceeding shall be on
19 the Designating Party. Frivolous challenges, and those made for an improper
20 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
21 parties) may expose the Challenging Party to sanctions. Likewise, a Designating
22 Party’s repeated over-designation of documents, thereby causing the Challenging
23 Party to repeatedly challenge such over-designations, may expose the Designating
24 Party to sanctions. Unless the Designating Party has waived or withdrawn the
25 confidentiality designation, all parties shall continue to afford the material in
26 question the level of protection to which it is entitled under the Producing Party’s
27 designation until the Court rules on the challenge.
1 7. ACCESS TO AND USE OF PROTECTED MATERIAL
2 7.1 Basic Principles. A Receiving Party may use Protected Material that is
3 disclosed or produced by another Party or by a Non-Party in connection with this
4 Action only for prosecuting, defending or attempting to settle this Action. Such
5 Protected Material may be disclosed only to the categories of persons and under the
6 conditions described in this Order. When the Action has been terminated, a
7 Receiving Party must comply with the provisions of section 13 below (FINAL
8 DISPOSITION).
9 Protected Material must be stored and maintained by a Receiving Party at a
10 location and in a secure manner that ensures that access is limited to the persons
11 authorized under this Order. Copies of “HIGHLY CONFIDENTIAL –
12 ATTORNEYS’ EYES ONLY” Information shall be maintained at the offices of
13 Plaintiff’s and Defendants’ respective Outside Counsel of Record in a secure
14 manner that ensures access is limited to the persons authorized under this Order.
15 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
16 otherwise ordered by the court or permitted in writing by the Designating Party, a
17 Receiving Party may disclose any information or item designated
18 “CONFIDENTIAL” only to:
19 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
20 well as employees of said Outside Counsel of Record to whom it is reasonably
21 necessary to disclose the information for this Action;
22 (b) the officers, directors, and employees (including House Counsel) of
23 the Receiving Party to whom disclosure is reasonably necessary for this Action;
24 (c) Experts (as defined in this Order) of the Receiving Party to whom
25 disclosure is reasonably necessary for this Action and who have signed the
26 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
27 (d) the court and its personnel where disclosure is reasonably necessary
1 (e) court reporters and their staff where disclosure is reasonably necessary
2 for this Action;
3 (f) professional jury or trial consultants, mock jurors, and Professional
4 Vendors to whom disclosure is reasonably necessary for this Action and who have
5 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
6 (g) the author or recipient of a document containing the information or a
7 custodian or other person who otherwise possessed or knew the information;
8 (h) during their depositions, witnesses, and attorneys for witnesses, in the
9 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
10 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
11 will not be permitted to keep any confidential information unless they sign the
12 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
13 agreed by the Designating Party or ordered by the court. Pages of transcribed
14 deposition testimony or exhibits to depositions that reveal Protected Material may
15 be separately bound by the court reporter and may not be disclosed to anyone except
16 as permitted under this Stipulated Protective Order; and
17 (i) any mediator or settlement officer, and their supporting personnel,
18 mutually agreed upon by any of the parties engaged in settlement discussions.
19 (j) any other person with the prior written consent of the Designating Party
20
21 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
22 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in
23 writing by the Designating Party, a Receiving Party may disclose any information or
24 item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only
25 to:
26 (a) the Receiving Party’s Outside Counsel of Record in this Action,
27 as well as employees of said Outside Counsel of Record to whom it is reasonably
1 (b) Experts (as defined in this Order) of the Receiving Party to
2 whom disclosure is reasonably necessary for this Action and who have signed the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (c) Professional Vendors (as defined in this Order) to whom
5 disclosure is reasonably necessary for this Action and who have signed the
6 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
7 (d) the court and its personnel where disclosure is reasonably
8 necessary for this Action;
9 (e) any other person with the prior written consent of the
10 Designating Party.
11
12 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
13 IN OTHER LITIGATION
14 If a Party is served with a subpoena or a court order issued in other litigation
15 that compels disclosure of any information or items designated in this Action as
16 “CONFIDENTIAL” and/or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
17 ONLY,” that Party must:
18 (a) promptly notify in writing the Designating Party. Such notification
19 shall include a copy of the subpoena or court order;
20 (b) promptly notify in writing the party who caused the subpoena or order
21 to issue in the other litigation that some or all of the material covered by the
22 subpoena or order is subject to this Protective Order. Such notification shall include
23 a copy of this Stipulated Protective Order; and
24 (c) cooperate with respect to all reasonable procedures sought to be
25 pursued by the Designating Party whose Protected Material may be affected.
26 If the Designating Party timely seeks a protective order, the Party served with
27 the subpoena or court order shall not produce any information designated in this
1 ATTORNEYS’ EYES ONLY,” before a determination by the court from which the
2 subpoena or order issued, unless the Party has obtained the Designating Party’s
3 permission. The Designating Party shall bear the burden and expense of seeking
4 protection in that court of its confidential material and nothing in these provisions
5 should be construed as authorizing or encouraging a Receiving Party in this Action
6 to disobey a lawful directive from another court.
7
8 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
9 PRODUCED IN THIS LITIGATION
10 (a) The terms of this Order are applicable to information produced by a
11 Non-Party in this Action and designated as “CONFIDENTIAL” and/or “HIGHLY
12 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by
13 Non-Parties in connection with this litigation is protected by the remedies and relief
14 provided by this Order. Nothing in these provisions should be construed as
15 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-Party
21 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.
1 14 days of receiving the notice and accompanying information, the Receiving Party
2 may produce the Non-Party’s confidential information responsive to the discovery
3 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
4 not produce any information in its possession or control that is subject to the
5 confidentiality agreement with the Non-Party before a determination by the court.
6 Absent a court order to the contrary, the Non-Party shall bear the burden and
7 expense of seeking protection in this court of its Protected Material.
8
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
19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
20 PROTECTED MATERIAL
21 When a Producing Party gives notice to Receiving Parties that certain
22 inadvertently produced material is subject to a claim of privilege or other protection,
23 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
24 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
25 procedure may be established in an e-discovery order that provides for production
26 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
27 (e), insofar as the parties reach an agreement on the effect of disclosure of a
1 product protection, the parties may incorporate their agreement in the stipulated
2 protective order submitted to the court.
3
4 12. MISCELLANEOUS
5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
6 person to seek its modification by the Court in the future.
7 12.2 Right to Assert Other Objections. By stipulating to the entry of this
8 Protective Order, no Party waives any right it otherwise would have to object to
9 disclosing or producing any information or item on any ground not addressed in this
10 Stipulated Protective Order. Similarly, no Party waives any right to object on any
11 ground to use in evidence of any of the material covered by this Protective Order.
12 12.3 Filing Protected Material. A Party that seeks to file under seal any
13 Protected Material must comply with Local Civil Rule 79-5. Protected Material
14 may only be filed under seal pursuant to a court order authorizing the sealing of the
15 specific Protected Material at issue. If a Party’s request to file Protected Material
16 under seal is denied by the court, then the Receiving Party may file the information
17 in the public record unless otherwise instructed by the court.
18
19 13. FINAL DISPOSITION
20 After the final disposition of this Action, as defined in paragraph 4, within 60
21 days of a written request by the Designating Party, each Receiving Party must return
22 all Protected Material to the Producing Party or destroy such material. As used in
23 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
24 summaries, and any other format reproducing or capturing any of the Protected
25 Material. Whether the Protected Material is returned or destroyed, the Receiving
26 Party must submit a written certification to the Producing Party (and, if not the same
27 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
1 destroyed and (2) affirms that the Receiving Party has not retained any copies,
2 abstracts, compilations, summaries or any other format reproducing or capturing any
3 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
4 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
5 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
6 reports, attorney work product, and consultant and expert work product, even if such
7 materials contain Protected Material. Any such archival copies that contain or
8 constitute Protected Material remain subject to this Protective Order as set forth in
9 Section 4 (DURATION).
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1 || 14. VIOLATION
2 |} Any violation of this Order may be punished by appropriate measures including,
3 |} without limitation, contempt proceedings and/or monetary sanctions.
4
5 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6
7 Dated: November 23, 2020 LEJEUNE LAW, P.C.

. By. CL ZS
CODY R. LEJEUNE
9 Attorneys for Plaintiff
ANTHONY LONGO, individually and
10 derivatively on behalf of TODOS SANTOS
SURF, INC.
|| Dated: November 23,2020 | ROPERS MAJES KI PC
13 ;
14 2 ee Se
By: ae
15 ANDREW S. HOLLINS
JAMES C. HILDEBRAND
16 ETHAN A. REIMERS
Attomeys for Defendants
17 VINCENT LONGO and FUTURE FIN
SYSTEMS PTY LTD
18
19
99 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
21
09 DATED: November 25, 2020
3 || Rapelis, OL
HON. ROZELLA A. OLIVER
25 || United States Magistrate Judge
26
27
28

1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [print or type full name], of
5 _________________ [print or type full address], declare under penalty of perjury
6 that I have read in its entirety and understand the Stipulated Protective Order that
7 was issued by the United States District Court for the Central District of California
8 on [date] in the case of Anthony Longo v. Vincent Longo; Future Fin Systems Pty
9 Ltd, Case No. 20-cv-00829-AB-RAO. I agree to comply with and to be bound by
10 all the terms of this Stipulated Protective Order and I understand and acknowledge
11 that failure to so comply could expose me to sanctions and punishment in the nature
12 of contempt. I solemnly promise that I will not disclose in any manner any
13 information or item that is subject to this Stipulated Protective Order to any person
14 or entity except in strict compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court for the
16 Central District of California for enforcing the terms of this Stipulated Protective
17 Order, even if such enforcement proceedings occur after termination of this action.
18 I hereby appoint __________________________ [print or type full name] of
19 _______________________________________ [print or type full address and
20 telephone number] as my California agent for service of process in connection with
21 this action or any proceedings related to enforcement of this Stipulated Protective
22 Order.
23 Date: ______________________________________
24 City and State where sworn and signed: _________________________________
25
26 Printed name: _______________________________
27

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10039585. Public record. Not legal advice.