even stipulated protective orders require 18 good cause showing
How later courts described this case
- even stipulated protective orders require 18 good cause showing
Written by the judges who cited it.
The opinion
1 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
PAUL S. COWIE, SBN 250131
2 pcowie@sheppardmullin.com
379 Lytton Avenue
3 Palo Alto, CA 94301-1479
Telephone: 650.815.2600
4 Facsimile: 650.815.2601
5 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
FATEMEH S, MASHOUF, SBN 288667
6 fmashouf@sheppardmullin.com
333 South Hope Street, 43rd Floor
7 Los Angeles, CA 90071-1422
Telephone: 213.620.1780
8 Facsimile: 213.620.1398
9 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
PETER LEE, SBN 318853
10 plee@sheppardmullin.com
Four Embarcadero Center, 17th Floor
11 San Francisco, CA 94111
Telephone: 415.434.9100
12 Facsimile: 415.434.3947
13 Attorneys for Defendant BENCHMARK
ELECTRONICS MANUFACTURING
14 SOLUTIONS, INC.
15 Additional Counsel Listed on Next Page
16 UNITED STATES DISTRICT COURT
17 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
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JOACHIM POSADAS, an individual; Case No. 2:21-cv-02164 MCS(RAOx)
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Plaintiff, Honorable Mark C. Scarsi, Crtrm 7C
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v.
21 STIPULATED PROTECTIVE
BENCHMARK ELECTRONICS ORDER1
22 MANUFACTURING SOLUTIONS,
INC., DOES 1 through 50, Inclusive,
23
Defendants. Complaint Filed: February 3, 2021
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27 1 This Stipulated Protective Order is substantially based on the model protective
order provided under Magistrate Judge Rozella A. Oliver’s Procedures with
1 LAW OFFICE OF SETH E. TILLMON
Seth E. Tillmon, SBN 246240
2 seth@tillmonlaw.com
16350 Ventura Blvd., Suite D
3 Encino, CA 91436
Telephone; (818) 849-6277
4 Facsimile: (424) 675-2811
5 Attorney for Plaintiff
JOACHIM POSADAS
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1 1. A. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 proprietary or private information for which special protection from public disclosure
4 and from use for any purpose other than prosecuting this litigation may be warranted.
5 Accordingly, the parties hereby stipulate to and petition the Court to enter the
6 following Stipulated Protective Order. The parties acknowledge that this Order does
7 not confer blanket protections on all disclosures or responses to discovery and that
8 the protection it affords from public disclosure and use extends only to the limited
9 information or items that are entitled to confidential treatment under the applicable
10 legal principles.
11 B. GOOD CAUSE STATEMENT
12 This action is likely to involve trade secrets, customer and pricing lists and
13 other valuable research, development, commercial, financial, technical and/or
14 proprietary information for which special protection from public disclosure and from
15 use for any purpose other than prosecution of this action is warranted. Such
16 confidential and proprietary materials and information consist of, among other
17 things, confidential business or financial information, information regarding
18 confidential business practices, or other confidential research, development, or
19 commercial information (including information implicating privacy rights of third
20 parties), information otherwise generally unavailable to the public, or which may be
21 privileged or otherwise protected from disclosure under state or federal statutes, court
22 rules, case decisions, or common law. Accordingly, to expedite the flow of
23 information, to facilitate the prompt resolution of disputes over confidentiality of
24 discovery materials, to adequately protect information the parties are entitled to keep
25 confidential, to ensure that the parties are permitted reasonable necessary uses of
26 such material in preparation for and in the conduct of trial, to address their handling
27 at the end of the litigation, and serve the ends of justice, a protective order for such
1 will not be designated as confidential for tactical reasons and that nothing be so
2 designated without a good faith belief that it has been maintained in a confidential,
3 non-public manner, and there is good cause why it should not be part of the public
4 record of this case.
5 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
6 SEAL
7 The parties further acknowledge, as set forth in Section 12.3, below, that this
8 Stipulated Protective Order does not entitle them to file confidential information
9 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and
10 the standards that will be applied when a party seeks permission from the court to
11 file material under seal.
12 There is a strong presumption that the public has a right of access to judicial
13 proceedings and records in civil cases. In connection with non-dispositive motions,
14 good cause must be shown to support a filing under seal. See Kamakana v. City and
15 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
16 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics,
17 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require
18 good cause showing), and a specific showing of good cause or compelling reasons
19 with proper evidentiary support and legal justification, must be made with respect to
20 Protected Material that a party seeks to file under seal. The parties’ mere designation
21 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the
22 submission of competent evidence by declaration, establishing that the material
23 sought to be filed under seal qualifies as confidential, privileged, or otherwise
24 protectable—constitute good cause.
25 Further, if a party requests sealing related to a dispositive motion or trial, then
26 compelling reasons, not only good cause, for the sealing must be shown, and the
27 relief sought shall be narrowly tailored to serve the specific interest to be protected.
1 each item or type of information, document, or thing sought to be filed or introduced
2 under seal in connection with a dispositive motion or trial, the party seeking
3 protection must articulate compelling reasons, supported by specific facts and legal
4 justification, for the requested sealing order. Again, competent evidence supporting
5 the application to file documents under seal must be provided by declaration.
6 Any document that is not confidential, privileged, or otherwise protectable in
7 its entirety will not be filed under seal if the confidential portions can be redacted. If
8 documents can be redacted, then a redacted version for public viewing, omitting only
9 the confidential, privileged, or otherwise protectable portions of the document shall
10 be filed. Any application that seeks to file documents under seal in their entirety
11 should include an explanation of why redaction is not feasible.
12 2. DEFINITIONS
13 2.1 Action: Joachim Posadas v. Benchmark Electronics Manufacturing
14 Solutions, Inc., Case No. CV 21-02165 CAS (RAO)
15 2.2 Challenging Party: a Party or Non-Party that challenges the designation
16 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 the
20 Good Cause Statement.
21 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
22 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 among other things, testimony, transcripts, and tangible things) that are produced or
2 generated in disclosures or responses to discovery in this matter.
3 2.7 Expert: a person with specialized knowledge or experience in a matter
4 pertinent to the litigation who has been retained by a Party or its counsel to serve as
5 an expert witness or as a consultant in this Action.
6 2.8 House Counsel: attorneys who are employees of a party to this Action.
7 House Counsel does not include Outside Counsel of Record or any other outside
8 counsel.
9 2.9 Non-Party: any natural person, partnership, corporation, association or
10 other legal entity not named as a Party to this action.
11 2.10 Outside Counsel of Record: attorneys who are not employees of a party
12 to this Action but are retained to represent or advise a party to this Action and have
13 appeared in this Action on behalf of that party or are affiliated with a law firm that
14 has appeared on behalf of that party, and includes support staff.
15 2.11 Party: any party to this Action, including all of its officers, directors,
16 employees, consultants, retained experts, and Outside Counsel of Record (and their
17 support staffs).
18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
19 Discovery Material in this Action.
20 2.13 Professional Vendors: persons or entities that provide litigation support
21 services (e.g., photocopying, videotaping, translating, preparing exhibits or
22 demonstrations, and organizing, storing, or retrieving data in any form or medium)
23 and their employees and subcontractors.
24 2.14 Protected Material: any Disclosure or Discovery Material that is
25 designated as “CONFIDENTIAL.”
26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
27 from a Producing Party.
1 3. SCOPE
2 The protections conferred by this Stipulation and Order cover not only
3 Protected Material (as defined above), but also (1) any information copied or
4 extracted from Protected Material; (2) all copies, excerpts, summaries, or
5 compilations of Protected Material; and (3) any testimony, conversations, or
6 presentations by Parties or their Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the
8 trial judge. This Order does not govern the use of Protected Material at trial.
9 4. DURATION
10 Even after final disposition of this litigation, the confidentiality obligations
11 imposed by this Order shall remain in effect until a Designating Party agrees
12 otherwise in writing or a court order otherwise directs. Final disposition shall be
13 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
14 or without prejudice; and (2) final judgment herein after the completion and
15 exhaustion of all appeals, re-hearings, remands, trials, or reviews of this Action,
16 including the time limits for filing any motions or applications for extension of time
17 pursuant to applicable law.
18 5. DESIGNATING PROTECTED MATERIAL
19 5.1 Exercise of Restraint and Care in Designating Material for Protection.
20 Each Party or Non-Party that designates information or items for protection under
21 this Order must take care to limit any such designation to specific material that
22 qualifies under the appropriate standards. The Designating Party must designate for
23 protection only those parts of material, documents, items or oral or written
24 communications that qualify so that other portions of the material, documents, items
25 or communications for which protection is not warranted are not swept unjustifiably
26 within the ambit of this Order.
27 Mass, indiscriminate or routinized designations are prohibited. Designations
1 purpose (e.g., to unnecessarily encumber the case development process or to impose
2 unnecessary expenses and burdens on other parties) may expose the Designating
3 Party to sanctions.
4 If it comes to a Designating Party’s attention that information or items that it
5 designated for protection do not qualify for protection, that Designating Party must
6 promptly notify all other Parties that it is withdrawing the inapplicable designation.
7 5.2 Manner and Timing of Designations. Except as otherwise provided in
8 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
9 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
10 under this Order must be clearly so designated before the material is disclosed or
11 produced.
12 Designation in conformity with this Order requires:
13 (a) for information in documentary form (e.g., paper or electronic documents,
14 but excluding transcripts of depositions or other pretrial or trial proceedings), that the
15 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
16 “CONFIDENTIAL legend”), to each page that contains protected material. If only
17 a portion of the material on a page qualifies for protection, the Producing Party also
18 must clearly identify the protected portion(s) (e.g., by making appropriate markings
19 in the margins).
20 A Party or Non-Party that makes original documents available for inspection
21 need not designate them for protection until after the inspecting Party has indicated
22 which documents it would like copied and produced. During the inspection and
23 before the designation, all of the material made available for inspection shall be
24 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
25 documents it wants copied and produced, the Producing Party must determine which
26 documents, or portions thereof, qualify for protection under this Order. Then, before
27 producing the specified documents, the Producing Party must affix the
1 portion of the material on a page qualifies for protection, the Producing Party also
2 must clearly identify the protected portion(s) (e.g., by making appropriate markings
3 in the margins).
4 This provision includes where a Party seeks the production of email data with
5 little or no narrowing of the emails. If the producing Party agrees to make a large
6 production (i.e. exceeding 500 items), the Producing Party may agree to produce all
7 information as “CONFIDENTIAL” and provide the documents with bates stamps.
8 After the inspecting Party has identified the documents it wants copied and produced,
9 the Producing Party must determine which documents, or portions thereof, qualify
10 for protection under this Order. Then, before producing the specified documents, the
11 Producing Party must affix the “CONFIDENTIAL legend” to each page that contains
12 Protected Material. If the inspecting Party wants copied and produced more than 250
13 pages of documents and making individualized confidentiality assessments for each
14 document is likely to take ten or more hours, the Producing Party may designate all
15 documents CONFIDENTIAL to avoid the burden of individual confidential
16 designation.
17 (b) for testimony given in depositions that the Designating Party identifies the
18 Disclosure or Discovery Material on the record, before the close of the deposition all
19 protected testimony.
20 (c) for information produced in some form other than documentary and for any
21 other tangible items, that the Producing Party affix in a prominent place on the
22 exterior of the container or containers in which the information is stored the legend
23 “CONFIDENTIAL.” If only a portion or portions of the information warrants
24 protection, the Producing Party, to the extent practicable, shall identify the protected
25 portion(s).
26 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
27 failure to designate qualified information or items does not, standing alone, waive
1 Upon timely correction of a designation, the Receiving Party must make reasonable
2 efforts to assure that the material is treated in accordance with the provisions of this
3 Order.
4 5.4 At any time in the Action, a Producing Party may waive or withdraw the
5 confidentiality designation by informing the non-Producing Party in writing of the
6 specific materials for which the designation is being removed/altered. The non-
7 Producing Party shall have up to five business days to request that the confidentiality
8 designation remain; in such a case, the non-Producing Party becomes the Producing
9 Party for purposes of any procedures for dealing with the designation as dictated in
10 the Protective Order. Parties need not seek Court intervention in order to alter a
11 confidentiality designation where neither Party has objected to the change pursuant
12 to this paragraph or where it is the Producing Party that has given notice to remove
13 the confidentiality designation.
14 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
15 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
16 designation of confidentiality at any time. Unless a prompt challenge to a
17 Designating Party’s confidentiality designation is necessary to avoid foreseeable,
18 substantial unfairness, unnecessary economic burdens, or a significant disruption or
19 delay of the litigation, a Party does not waive its right to challenge a confidentiality
20 designation by electing not to mount a challenge promptly after the original
21 designation is disclosed.
22 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
23 resolution process under Local Rule 37.1 et seq.
24 6.3 The burden of persuasion in any such challenge proceeding shall be on
25 the Designating Party. Frivolous challenges, and those made for an improper
26 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties)
27 may expose the Challenging Party to sanctions. Unless the Designating Party has
1 afford the material in question the level of protection to which it is entitled under the
2 Producing Party’s designation until the Court rules on the challenge.
3 7. ACCESS TO AND USE OF PROTECTED MATERIAL
4 7.1 Basic Principles. A Receiving Party may use Protected Material that is
5 disclosed or produced by another Party or by a Non-Party in connection with this
6 Action only for prosecuting, defending or attempting to settle this Action. Such
7 Protected Material may be disclosed only to the categories of persons and under the
8 conditions described in this Order. When the Action has been terminated, a
9 Receiving Party must comply with the provisions of section 13 below (FINAL
10 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, as well as
19 employees of said Outside Counsel of Record to whom it is reasonably necessary to
20 disclose the information for this Action;
21 (b) the officers, directors, and employees (including House Counsel) of the
22 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;
1 (f) professional jury or trial consultants, mock jurors, and Professional Vendors
2 to whom disclosure is reasonably necessary for this Action and who have signed the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (g) the author or recipient of a document containing the information or a
5 custodian or other person who otherwise possessed or knew the information;
6 (h) during their depositions, witnesses, and attorneys for witnesses, in the
7 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
9 (2) they will not be permitted to keep any confidential information unless they
10 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
11 otherwise agreed by the Designating Party or ordered by the court. Pages of
12 transcribed deposition testimony or exhibits to depositions that reveal Protected
13 Material may be separately bound by the court reporter and may not be
14 disclosed to anyone except as permitted under this Stipulated Protective Order;
15 and
16 (i) any mediator or settlement officer, and their supporting personnel, mutually
17 agreed upon by any of the parties engaged in settlement discussions.
18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
19 PRODUCED IN OTHER LITIGATION
20 If a Party is served with a subpoena or a court order issued in other litigation
21 that compels disclosure of any information or items designated in this Action as
22 “CONFIDENTIAL,” that Party must:
23 (a) promptly notify in writing the Designating Party. Such notification shall
24 include a copy of the subpoena or court order;
25 (b) promptly notify in writing the party who caused the subpoena or order to
26 issue in the other litigation that some or all of the material covered by the subpoena
27 or order is subject to this Protective Order. Such notification shall include a copy of
1 (c) cooperate with respect to all reasonable procedures sought to be pursued
2 by the Designating Party whose Protected Material may be affected.
3 If the Designating Party timely seeks a protective order, the Party served with
4 the subpoena or court order shall not produce any information designated in this
5 action as “CONFIDENTIAL” before a determination by the court from which the
6 subpoena or order issued, unless the Party has obtained the Designating Party’s
7 permission. The Designating Party shall bear the burden and expense of seeking
8 protection in that court of its confidential material and nothing in these provisions
9 should be construed as authorizing or encouraging a Receiving Party in this Action
10 to disobey a lawful directive from another court.
11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
12 PRODUCED IN THIS LITIGATION
13 (a) The terms of this Order are applicable to information produced by a Non-
14 Party in this Action and designated as “CONFIDENTIAL.” Such information
15 produced by Non-Parties in connection with this litigation is protected by the
16 remedies and relief provided by this Order. Nothing in these provisions should be
17 construed as prohibiting a Non-Party from seeking additional protections.
18 (b) In the event that a Party is required, by a valid discovery request, to produce
19 a Non-Party’s confidential information in its possession, and the Party is subject to
20 an agreement with the Non-Party not to produce the Non-Party’s confidential
21 information, then the Party shall:
22 (1) promptly notify in writing the Requesting Party and the Non-Party that
23 some or all of the information requested is subject to a confidentiality agreement with
24 a Non-Party;
25 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
26 Order in this Action, the relevant discovery request(s), and a reasonably specific
27 description of the information requested; and
1 (3) make the information requested available for inspection by the Non-Party,
2 if requested.
3 (c) If the Non-Party fails to seek a protective order from this court within 14
4 days of receiving the notice and accompanying information, the Receiving Party may
5 produce the Non-Party’s confidential information responsive to the discovery
6 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
7 not produce any information in its possession or control that is subject to the
8 confidentiality agreement with the Non-Party before a determination by the court.
9 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
10 of seeking protection in this court of its Protected Material.
11 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
13 Protected Material to any person or in any circumstance not authorized under this
14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
15 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
16 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
17 persons to whom unauthorized disclosures were made of all the terms of this Order,
18 and (d) request such person or persons to execute the “Acknowledgment and
19 Agreement to Be Bound” that is attached hereto as Exhibit A.
20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
21 OTHERWISE PROTECTED MATERIAL
22 When a Producing Party gives notice to Receiving Parties that certain
23 inadvertently produced material is subject to a claim of privilege or other protection,
24 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
25 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
26 may be established in an e-discovery order that provides for production without prior
27 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
1 information covered by the attorney-client privilege or work product protection, the
2 parties may incorporate their agreement in the stipulated protective order submitted
3 to the court.
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 2.3 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 may
14 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 13. FINAL DISPOSITION
19 After the final disposition of this Action, as defined in paragraph 4
20 (DURATION), within 60 days of a written request by the Designating Party, each
21 Receiving Party must return all Protected Material to the Producing Party or destroy
22 such material. As used in this subdivision, “all Protected Material” includes all
23 copies, abstracts, compilations, summaries, and any other format reproducing or
24 capturing any of the Protected Material. Whether the Protected Material is returned
25 or destroyed, the Receiving Party must submit a written certification to the Producing
26 Party (and, if not the same person or entity, to the Designating Party) by the 60 day
27 deadline that (1) identifies (by category, where appropriate) all the Protected Material
|| retained any copies, abstracts, compilations, summaries or any other format
|| reproducing or capturing any of the Protected Material. Notwithstanding this
|| provision, Counsel are entitled to retain an archival copy of all pleadings, motion
4]| papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
5}| deposition and trial exhibits, expert reports, attorney work product, and consultant
6}| and expert work product, even if such materials contain Protected Material. Any
such archival copies that contain or constitute Protected Material remain subject to
8 || this Protective Order as set forth in Section 4 (DURATION).
9 14. VIOLATION
10 Any violation of this Order may be punished by appropriate measures
11 }} including, without limitation, contempt proceedings and/or monetary sanctions.
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3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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15 DATED __ June 10, 2021 /s/ Seth E. Tillmon
Seth E. Tillmon |
16 Attorneys for Plaintiff
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19 DATED: __ June 10, 2021 /s/ Fatemeh S. Mahouf
Paul S. Cowie
20 Fatemeh S. Mashouf
Attorneys for Defendant
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3 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
Re Qo
95 || DATED: June 14, 2021 Rapelhs, dn,
Honorable Rozella A. Oliver
26 United States Magistrate Judge
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1 ATTORNEY ATTESTATION
2 Pursuant to Central District of California Civil Local Rule 5-4.3.4(a)(2)(i), I
3 hereby attest that all other signatories listed, and on whose behalf the filing is
4 submitted, concur in this document’s content and have authorized the filing of this
5 document.
6 DATED: June 10, 2021 /s/ Fatemeh S. Mahouf
Fatemeh S. Mashouf
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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 that
6 I have read in its entirety and understand the Stipulated Protective Order that was
7 issued by the United States District Court for the Central District of California on
8 [date] in the case of ___________ [insert formal name of the case and the number and
9 initials assigned to it by the court]. I agree to comply with and to be bound by all the
10 terms of this Stipulated Protective Order and I understand and acknowledge that
11 failure to so comply could expose me to sanctions and punishment in the nature of
12 contempt. I solemnly promise that I will not disclose in any manner any information
13 or item that is subject to this Stipulated Protective Order to any person or entity except
14 in strict compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for enforcing the terms of this Stipulated
17 Protective Order, even if such enforcement proceedings occur after termination of
18 this action. I hereby appoint __________________________ [print or type full
19 name] of _______________________________________ [print or type full address
20 and telephone number] as my California agent for service of process in connection
21 with this action or any proceedings related to enforcement of this Stipulated
22 Protective Order.
23 Date: _____________ sworn and signed: ________________________, California
24
Printed name: _______________________________
25
26 Signature: __________________________________
27