Opinion

Shahzad Zakir v. T-Mobile USA, Inc

Court
District Court, C.D. California
Filed
Jun 18, 2020
Cited by
0 cases
Authority
More cited than 31.2%

even stipulated 10 || protective orders require good cause showing

How later courts described this case

  • even stipulated 10 || protective orders require good cause showing

Written by the judges who cited it.

The opinion

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g UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10 SOUTHERN DIVISION

SHAHZAD ZAKIR, an individual, | CASE NO.: 8:20-CV-00411-JVS (JDE)

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Plaintiff, STIPULATED PROTECTIVE

12 ORDER

V.

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T-MOBILE USA, INC., a

14 Delaware corporation; and DOES 1

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Defendant.

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17 Pursuant to the parties’ Stipulation (Dkt. 15), and good cause appearing

18 || therefor, the Court finds and orders as follows.

19 1. | PURPOSES AND LIMITATIONS

20 Discovery in this action is likely to involve production of confidential,

21 proprietary or private information for which special protection from public

22 || disclosure and from use for any purpose other than pursuing this litigation may

23 || be warranted. Accordingly, the parties hereby stipulate to and petition the

24 | Court to enter the following Stipulated Protective Order. The parties

25 acknowledge that this Order does not confer blanket protections on all

26 |) disclosures or responses to discovery and that the protection it affords from

27 public disclosure and use extends only to the limited information or items that

28 || are entitled to confidential treatment under the applicable legal principles.

l 2. GOOD CAUSE STATEMENT

This action ts likely to involve medical records, trade secrets, customer

3 || and pricing lists and other valuable research, development, commercial,

4 || financial, technical and/or proprietary information for which special protection

5 || from public disclosure and from use for any purpose other than prosecution of

6 || this action is warranted. Such private, confidential, and proprietary materials

7 || and information consist of, among other things, medical information,

g || confidential business or financial information, information regarding

g || confidential business practices, or other confidential research, development, or

10 || commercial information (including information implicating privacy rights of

11 || third parties), information otherwise generally unavailable to the public, or

12 || which may be privileged or otherwise protected from disclosure under state or

13 || federal statutes, court rules, case decisions, or common law. This action is also

14 || likely to involve the private or confidential information of third-parties.

15 || Accordingly, to expedite the flow of information, to facilitate the prompt

16 || resolution of disputes over confidentiality of discovery materials, to adequately

17 || protect information the parties are entitled to keep confidential, to ensure that

18 || the parties are permitted reasonable necessary uses of such material in

19 || preparation for and in the conduct of trial, to address their handling at the end

20 || of the litigation, and serve the ends of justice, a protective order for such

21 || information is justified 1n this matter. It is the intent of the parties that

22 || information will not be designated as confidential for tactical reasons and that

23 || nothing be so designated without a good faith belief that it has been maintained

24 || in a confidential, non-public manner, and there is good cause why it should not

25 || be part of the public record of this case.

26 3. UNDER SEAL FILING PROCEDURE

27 The parties further acknowledge, as set forth in Section 14.3, below, that

28 || this Stipulated Protective Order does not entitle them to file confidential

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1 || mnformation under seal; Local Civil Rule 79-5 sets forth the procedures that

> || must be followed and the standards that will be applied when a party seeks

3 || permission from the court to file material under seal. There is a strong

4 || presumption that the public has a right of access to judicial proceedings and

5 || records in civil cases. In connection with non-dispositive motions, good cause

6 || must be shown to support a filing under seal. See Kamakana v. City and

7 || County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen.

g || Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony

g || Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated

10 || protective orders require good cause showing), and a specific showing of good

11 || cause or compelling reasons with proper evidentiary support and legal

12 || justification, must be made with respect to Protected Material that a party seeks

13 || to file under seal. The parties’ mere designation of Disclosure or Discovery

14 | Material as CONFIDENTIAL does not— without the submission of

15 || competent evidence by declaration, establishing that the material sought to be

16 || filed under seal qualifies as confidential, privileged, or otherwise protectable—

17 || constitute good cause.

18 Further, if a party requests sealing related to a dispositive motion or trial,

19 || then compelling reasons, not only good cause, for the sealing must be shown,

20 || and the relief sought shall be narrowly tailored to serve the specific interest to

21 || be protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th

22 || Cir. 2010). For each item or type of information, document, or thing sought to

23 || be filed or introduced under seal, the party seeking protection must articulate

24 || compelling reasons, supported by specific facts and legal justification, for the

25 || requested sealing order. Again, competent evidence supporting the application

26 || to file documents under seal must be provided by declaration.

27 || Any document that is not confidential, privileged, or otherwise protectable in

28 || its entirety will not be filed under seal if the confidential portions can be

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1 || redacted. If documents can be redacted, then a redacted version for public

4 || viewing, omitting only the confidential, privileged, or otherwise protectable

3 || portions of the document, shall be filed. Any application that seeks to file

4 || documents under seal in their entirety should include an explanation of why

5 || redaction is not feasible.

6 4, DEFINITIONS

7 4.1 Action: this pending federal lawsuit.

8 4.2 Challenging Party: a Party or Non-Party that challenges the

9 || designation of information or items under this Order.

10 4.3. “CONFIDENTIAL” Information or Items: information (regardless

11 || of how it is generated, stored or maintained) or tangible things that qualify for

12 || protection under Federal Rule of Civil Procedure 26(c), and as specified above

13 || in the Good Cause Statement.

14 4.4 Counsel: Outside Counsel of Record and House Counsel (as well

15 || as their support staff).

16 4.5 Designating Party: a Party or Non-Party that designates

17 || information or items that it produces in disclosures or in responses to discovery

18 || as “CONFIDENTIAL.”

19 4.6 Dizisclosure or Discovery Material: all items or information,

20 || regardless of the medium or manner in which it is generated, stored, or

21 || maintained (including, among other things, testimony, transcripts, and tangible

22 || things), that are produced or generated in disclosures or responses to discovery.

23 4.7 Expert: a person with specialized knowledge or experience ina

24 || matter pertinent to the litigation who has been retained by a Party or its counsel

25 || to serve as an expert witness or as a consultant in this Action.

26 4.8 House Counsel: attorneys, as well as their support staff, who are

27 || employees of a party to this Action. House Counsel does not include Outside

28 || Counsel of Record or any other outside counsel.

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l 4.9 Non-Party: any natural person, partnership, corporation,

4 || association or other legal entity not named as a Party to this action.

3 4.10 Outside Counsel of Record: attorneys who are not employees of a

4 || party to this Action but are retained to represent a party to this Action and have

5 || appeared in this Action on behalf of that party or are affiliated with a law firm

6 || that has appeared on behalf of that party, and includes support staff.

7 4.11 Party: any party to this Action, including all of its officers,

g || directors, employees, consultants, retained experts, and Outside Counsel of

9 || Record (and their support staffs).

10 4.12 Producing Party: a Party or Non-Party that produces Disclosure or

11 || Discovery Material in this Action.

12 4.13 Professional Vendors: persons or entities that provide litigation

13 || support services (e.g., photocopying, videotaping, translating, preparing

14 || exhibits or demonstrations, and organizing, storing, or retrieving data in any

15 || form or medium) and their employees and subcontractors.

16 4.14 Protected Material: any Disclosure or Discovery Material that is

17 || designated as “CONFIDENTIAL.”

18 4.15 Receiving Party: a Party that receives Disclosure or Discovery

19 || Material from a Producing Party.

20 5. SCOPE

21 The protections conferred by this Stipulation and Order cover not only

22 || Protected Material (as defined above), but also (1) any information copied or

23 || extracted from Protected Material; (2) all copies, excerpts, summaries, or

24 || compilations of Protected Material; and (3) any testimony, conversations, or

25 || presentations by Parties or their Counsel that might reveal Protected Material.

26 Any use of Protected Material at trial shall be governed by the orders of

27 || the trial judge and other applicable authorities. This Order does not govern the

28 || use of Protected Material at trial.

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l 6. DURATION

Once a case proceeds to trial, information that was designated as

3 | CONFIDENTIAL or maintained pursuant to this protective order used or

4 || introduced as an exhibit at trial becomes public and will be presumptively

5 || available to all members of the public, including the press, unless compelling

6 || reasons supported by specific factual findings to proceed otherwise are made to

7 || the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81

g || (distinguishing “good cause” showing for sealing documents produced in

g || discovery from “compelling reasons” standard when merits-related documents

10 || are part of court record). Accordingly, the terms of this protective order do not

11 || extend beyond the commencement of the trial.

12 7. DESIGNATING PROTECTED MATERIAL

13 7.1 Exercise of Restraint and Care in Designating Material for

14 Protection. Each Party or Non-Party that designates information or

15 || items for protection under this Order must take care to limit any such

16 || designation to specific material that qualifies under the appropriate standards.

17 || The Designating Party must designate for protection only those parts of

18 || material, documents, items or oral or written communications that qualify so

19 || that other portions of the material, documents, items or communications for

20 || which protection is not warranted are not swept unjustifiably within the ambit

21 |) of this Order.

22 Mass, indiscriminate or routinized designations are prohibited.

23 || Designations that are shown to be clearly unjustified or that have been made

24 || for an improper purpose (e.g., to unnecessarily encumber the case development

25 || process or to impose unnecessary expenses and burdens on other parties) may

26 || expose the Designating Party to sanctions.

27 If it comes to a Designating Party’s attention that information or items

28 || that it designated for protection do not qualify for protection, that Designating

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1 || Party must promptly notify all other Parties that it is withdrawing the

4 || inapplicable designation.

3 7.2 Manner and Timing of Designations. Except as otherwise provided

4 || in this Order, or as otherwise stipulated or ordered, Disclosure of Discovery

5 | Material that qualifies for protection under this Order must be clearly so

6 || designated before the material is disclosed or produced.

7 Designation in conformity with this Order requires:

8 (a) for information in documentary form (e.g., paper or electronic

g || documents, but excluding transcripts of depositions or other pretrial or trial

10 || proceedings), that the Producing Party affix at a minimum, the legend

11 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page

12 || that contains protected material. If only a portion of the material on a page

13 || qualifies for protection, the Producing Party also must clearly identify the

14 || protected portion(s) (e.g., by making appropriate markings in the margins).

15 A Party or Non-Party that makes original documents available for

16 || inspection need not designate them for protection until after the inspecting

17 || Party has indicated which documents it would like copied and produced.

18 || During the inspection and before the designation, all of the material made

19 || available for inspection shall be deemed “CONFIDENTIAL.” After the

20 || inspecting Party has identified the documents it wants copied and produced,

21 || the Producing Party must determine which documents, or portions thereof,

22 || qualify for protection under this Order. Then, before producing the specified

23 || documents, the Producing Party must affix the “CONFIDENTIAL legend” to

24 || each page that contains Protected Material. If only a portion of the material on

25 || a page qualifies for protection, the Producing Party also must clearly identify

26 || the protected portion(s) (e.g., by making appropriate markings in the margins).

27 (b) for testimony given in depositions that the Designating Party

28 || identifies the Disclosure or Discovery Material on the record, before the close

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1 || of the deposition all protected testimony.

(c) for information produced in some form other than documentary

3 || and for any other tangible items, that the Producing Party affix in a prominent

4 || place on the exterior of the container or containers in which the information is

5 || stored the legend “CONFIDENTIAL.” If only a portion or portions of the

6 || information warrants protection, the Producing Party, to the extent practicable,

7 || shall identify the protected portion(s).

8 7.3 Inadvertent Failures to Designate. If timely corrected, an

9 || inadvertent failure to designate qualified information or items does not,

10 || standing alone, waive the Designating Party’s right to secure protection under

11 || this Order for such material. Upon timely correction of a designation, the

12 || Receiving Party must make reasonable efforts to assure that the material is

13 || treated in accordance with the provisions of this Order.

14 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS

15 8.1. Timing of Challenges. Any Party or Non-Party may challenge a

16 || designation of confidentiality at any time that is consistent with the Court’s

17 || Scheduling Order.

18 8.2 Meet and Confer. The Challenging Party shall initiate the dispute

19 || resolution process under Local Rule 37-1 et seq.

20 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a

21 || joint stipulation pursuant to Local Rule 37-2.

22 8.4 The burden of persuasion in any such challenge proceeding shall be

23 || on the Designating Party. Frivolous challenges, and those made for an

24 || improper purpose (e.g., to harass or impose unnecessary expenses and burdens

25 || on other parties) may expose the Challenging Party to sanctions. Unless the

26 || Designating Party has waived or withdrawn the confidentiality designation, all

27 || parties shall continue to afford the material in question the level of protection to

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1 || which it is entitled under the Producing Party’s designation until the Court

7 || rules on the challenge.

3 9. ACCESS TO AND USE OF PROTECTED MATERIAL

4 9.1 Basic Principles. A Receiving Party may use Protected Material that

5 || is disclosed or produced by another Party or by a Non-Party in connection with

6 || this Action only for prosecuting, defending or attempting to settle this Action.

7 || Such Protected Material may be disclosed only to the categories of persons and

g || under the conditions described in this Order. When the Action has been

9 || terminated, a Receiving Party must comply with the provisions of section 15

10 || below (FINAL DISPOSITION).

11 Protected Material must be stored and maintained by a Receiving Party

12 || at a location and in a secure manner that ensures that access is limited to the

13 || persons authorized under this Order.

14 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

15 || otherwise ordered by the court or permitted in writing by the Designating

16 || Party, a 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

20 || reasonably necessary to disclose the information for this Action;

21 (b) the officers, directors, and employees (including House

22 || Counsel) of the Receiving Party to whom disclosure is reasonably necessary for

23 || this Action;

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

25 || whom disclosure is reasonably necessary for this Action and who have signed

26 || the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

27 (d) the court and its personnel;

28 (e) court reporters and their staff;

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l (f) professional jury or trial consultants, mock jurors, and

2 || Professional Vendors to whom disclosure is reasonably necessary for this

3 || Action and who have signed the “Acknowledgment and Agreement to Be

4 || Bound” (Exhibit A);

5 (g) the author or recipient of a document containing the

6 || information or a custodian or other person who otherwise possessed or knew

7 || the information;

g (h) during their depositions, witnesses, and attorneys for witnesses,

g || in the Action to whom disclosure is reasonably necessary provided: (1) the

10 || deposing party requests that the witness sign the form attached as Exhibit A

11 || hereto; and (2) they will not be permitted to keep any confidential information

12 || unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit

13 || A), unless otherwise agreed by the Designating Party or ordered by the court.

14 || Pages of transcribed deposition testimony or exhibits to depositions that reveal

15 || Protected Material may be separately bound by the court reporter and may not

16 || be disclosed to anyone except as permitted under this Stipulated Protective

17 || Order; and

18 (i) any mediators or settlement officers and their supporting

19 || personnel, mutually agreed upon by any of the parties engaged in settlement

20 || discussions.

21 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED

09 PRODUCED IN OTHER LITIGATION

73 If a Party is served with a subpoena or a court order issued in other

litigation that compels disclosure of any information or items designated in this

95 Action as “CONFIDENTIAL,” that Party must:

26 (a) promptly notify in writing the Designating Party. Such

77 notification shall include a copy of the subpoena or court order;

28 (b) promptly notify in writing the party who caused the subpoena

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1 || or order to issue in the other litigation that some or all of the material covered

4 || by the subpoena or order is subject to this Protective Order. Such notification

3 || shall include a copy of this Stipulated Protective Order; and

4 (c) cooperate with respect to all reasonable procedures sought to be

5 || pursued by the Designating Party whose Protected Material may be affected. If

6 || the Designating Party timely seeks a protective order, the Party served with the

7 || subpoena or court order shall not produce any information designated in this

g || action as “CONFIDENTIAL” before a determination by the court from which

9 || the subpoena or order issued, unless the Party has obtained the Designating

10 || Party’s permission. The Designating Party shall bear the burden and expense of

11 || seeking protection in that court of its confidential material and nothing in these

12 || provisions should be construed as authorizing or encouraging a Receiving Party

13 || 1n this Action to disobey a lawful directive from another court.

11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

15 PRODUCED IN THIS LITIGATION

16 (a) The terms of this Order are applicable to information produced

by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such

18 information produced by Non-Parties in connection with this litigation is

19 protected by the remedies and relief provided by this Order. Nothing in these

20 provisions should be construed as prohibiting a Non-Party from seeking

2! additional protections.

22 (b) In the event that a Party 1s required, by a valid discovery

request, to produce a Non-Party’s confidential information in its possession,

and the Party is subject to an agreement with the Non-Party not to produce the

Non-Party’s confidential information, then the Party shall:

*6 (1) promptly notify in writing the Requesting Party and the Non-

Party that some or all of the information requested is subject to a confidentiality

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1 || agreement with a Non-Party;

(2) promptly provide the Non-Party with a copy of the Stipulated

3 || Protective Order in this Action, the relevant discovery request(s), and a

4 || reasonably specific description of the information requested; and

5 (3) make the information requested available for inspection by the

6 || Non-Party, if requested.

7 (c) If the Non-Party fails to seek a protective order from this court

g || within 14 days of receiving the notice and accompanying information, the

9 || Receiving Party may produce the Non-Party’s confidential information

10 || responsive to the discovery request. If the Non-Party timely seeks a protective

11 || order, the Receiving Party shall not produce any information in its possession

12 || or control that is subject to the confidentiality agreement with the Non-Party

13 || before a determination by the court. Absent a court order to the contrary, the

14 || Non-Party shall bear the burden and expense of seeking protection in this court

15 || of its Protected Material.

16 12. UNAUTHORIZED DISCLOSURE OF PROTECTED

7 MATERIAL

18 If a Receiving Party learns that, by inadvertence or otherwise, it has

19 || disclosed Protected Material to any person or in any circumstance not

20 || authorized under this Stipulated Protective Order, the Receiving Party must

21 || immediately (a) notify in writing the Designating Party of the unauthorized

22 || disclosures, (b) use its best efforts to retrieve all unauthorized copies of the

23 || Protected Material, (c) inform the person or persons to whom unauthorized

24 || disclosures were made of all the terms of this Order, and (d) request such

25 || person or persons to execute the “Acknowledgment an Agreement to Be

26 || Bound” attached hereto as Exhibit A.

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l 13. INADVERTENT PRODUCTION OF PRIVILEGED OR

5 OTHERWISE PROTECTED MATERIAL

3 When a Producing Party gives notice to Receiving Parties that certain

4 || inadvertently produced material is subject to a claim of privilege or other

5 || protection, the obligations of the Receiving Parties are those set forth in Federal

6 || Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

7 || whatever procedure may be established in an e-discovery order that provides

g || for production without prior privilege review. Pursuant to Federal Rule of

9 || Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect

10 || of disclosure of a communication or information covered by the attorney-client

11 || privilege or work product protection, the parties may incorporate their

12 || agreement in the stipulated protective order submitted to the court.

13 14. MISCELLANEOUS

14 14.1 Right to Further Relief. Nothing in this Order abridges the right of

15 || any person to seek its modification by the Court in the future.

16 14.2 Right to Assert Other Objections. By stipulating to the entry of this

17 || Protective Order, no Party waives any right it otherwise would have to object to

18 || disclosing or producing any information or item on any ground not addressed

19 || in this Stipulated Protective Order. Similarly, no Party waives any right to

20 || object on any ground to use 1n evidence of any of the material covered by this

21 || Protective Order.

22 14.3 Filing Protected Material. A Party that seeks to file under seal any

23 || Protected Material must comply with Local Civil Rule 79-5. Protected Material

24 || may only be filed under seal pursuant to a court order authorizing the sealing of

25 || the specific Protected Material. If a Party’s request to file Protected Material

26 || under seal is denied by the court, then the Receiving Party may file the

27 || information in the public record unless otherwise instructed by the court.

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1 15. FINAL DISPOSITION

After the final disposition of this Action, as defined in paragraph 6,

3 || within 60 days of a written request by the Designating Party, each Receiving

4 || Party must return all Protected Material to the Producing Party or destroy such

5 || material. As used in this subdivision, “all Protected Material” includes all

6 || copies, abstracts, compilations, summaries, and any other format reproducing

7 || or capturing any of the Protected Material. Whether the Protected Material is

g || returned or destroyed, the Receiving Party must submit a written certification

9 || to the Producing Party (and, if not the same person or entity, to the Designating

10 || Party) by the 60-day deadline that (1) identifies (by category, where

11 || appropriate) all the Protected Material that was returned or destroyed and (2)

12 || affirms that the Receiving Party has not retained any copies, abstracts,

13 || compilations, summaries or any other format reproducing or capturing any of

14 || the Protected Material. Notwithstanding this provision, Counsel are entitled to

15 || retain an archival copy of all pleadings, motion papers, trial, deposition, and

16 || hearing transcripts, legal memoranda, correspondence, deposition and trial

17 || exhibits, expert reports, attorney work product, and consultant and expert work

18 || product, even if such materials contain Protected Material. Any such archival

19 || copies that contain or constitute Protected Material remain subject to this

20 || Protective Order as set forth in Section 6 (DURATION).

21 16. VIOLATION

22 Any violation of this Order may be punished by appropriate measures

23 || including, without limitation, contempt proceedings and/or monetary sanctions

24 FOR GOOD CAUSE SHOWN, IT IS SO OE .

2 DATED: June 18, 2020 Liu L a6

26 OHN D. EARLY

27 United States Magistrate Judge

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1 SHAHZAD ZAKIR, an individual, CASE NO.: 8:20-CV-00411-JVS (JDE)

Plaintiff,

3 V. EXHIBIT A

A T-MOBILE USA, INC., a Delaware

corporation; and DOES 1 - 50,

5 Defendant.

6

7 EXHIBIT A

8 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

? I, [FULL NAME], of

10 [POSITION AND EMPLOYER], declare that I have read in its entirety and

understand the Stipulated Protective Order that was issued by the United States

District Court for the Central District of California on June 18, 2020, in Shahzad

13 Zakir v. T-Mobile USA, Inc., Case No. 8:20-CV-00411-JVS (JDE). I agree to

comply with and to be bound by all the terms of this Stipulation and Protective

IS Order and I understand and acknowledge that failure to so comply could expose

16

me to sanctions and punishment in the nature of contempt. I solemnly promise that

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I will not disclose in any manner any information or item that is subject to this

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Stipulation and Protective Order to any person or entity except in strict compliance

19 with the provisions of this Order. I further agree to submit to the jurisdiction of

20 the United States District Court for the Central District of California, for the

71 purpose of enforcing the terms of this Stipulation and Protective Order, even if

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such enforcement proceedings occur after termination of this action.

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//

24 )

25 /

26 /

27 /

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1 I declare under penalty of perjury, under the laws of the State of California,

that the foregoing is true and correct. Executed this __, day of □

3 20___, at , _____-

“| DATED: BY:

5 Signature

° Title

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° City, State Zip

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DG

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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