The opinion
1 KENDRA S. CANAPE (SBN: 259641)
kcanape@grsm.com
2 JOEL D. BRODFUEHRER (SBN: 343092)
jbrodfuehrer@grsm.com
3 GORDON REES SCULLY MANSUKHANI, LLP
5 Park Plaza, Suite 1100
4 Irvine, CA 92614
Telephone: (949) 255-6950
5 Facsimile: (949) 474-2060
6 Attorneys for Defendant
IQ DATA INTERNATIONAL, INC.
7
8
UNITED STATES DISTRICT COURT
9
CENTRAL DISTRICT OF CALIFORNIA
10
11
SHEREE ALI, ) CASE NO.: 2:24-cv-00391-CBM-KS
)
12 Plaintiff, ) Judge: Hon. Consuelo B. Marshall
)
13 v. ) M agistrate: Hon. Karen L. Stevenson
14 PORTSIDE PARTNERS VENTURA, ) STIPULATED PROTECTIVE
) ORDER
15 HARBOR LLC; GREYSTAR )
MANAGEMENT SERVICES L.P.; (PVC VERSION 4/20)
)
16 I.Q. DATA INTERNATIONAL INC.; ) ☒ Check if submitted without
17 EQUIFAX INFORMATION ) material modifications to PVC form
SERVICES, LLC; EXPERIAN )
18 INFORMATION SOLUTIONS, INC.; )
19 TRANS UNION, LLC; AND DOES 1- )
10 )
20 )
)
21 Defendants. )
)
22
)
23 1. INTRODUCTION
24 1.1 PURPOSES AND LIMITATIONS
25 Discovery in this action is likely to involve production of confidential,
26 proprietary, or private information for which special protection from public
27 disclosure and from use for any purpose other than prosecuting this litigation may
28
1 enter the following Stipulated Protective Order. The parties acknowledge that this
2 Order does not confer blanket protections on all disclosures or responses to
3 discovery and that the protection it affords from public disclosure and use extends
4 only to the limited information or items that are entitled to confidential treatment
5 under the applicable legal principles.1
6 1.2 GOOD CAUSE STATEMENT
7 This action is likely to involve materials and information that I.Q. Data
8 International, Inc. (“IQ Data”) maintains as confidential for which special
9 protection from public disclosure and from use for any purpose other than
10 prosecution of this action is warranted. IQ Data may be producing documents
11 to Plaintiff that consist of, among other things, confidential business or
12 financial information, trade secrets, information regarding confidential
13 business practices, or other confidential research, development, or
14 commercial information, information otherwise generally unavailable to the
15 public, or which may be privileged or otherwise protected from disclosure
16 under state or federal statutes, court rules, case decisions, or common law. IQ
17 Data has maintained this information as confidential due to the sensitive
18 nature of the information. IQ Data’s competitors would gain an improper
19 advantage if documents were made public, including but not limited to
20 customer information, account notes, intellectual property, research,
21 technical, commercial, or financial information, business plans, business
22 policies, training materials, and other business-related information that are
23 not generally available to the public. The debt collection industry and
24 consumer reporting agencies are highly competitive and require
25 confidentiality of very sensitive consumer information. Plaintiff will also be
26 producing materials relating to or regarding Plaintiff’s debt(s), credit history,
27
28 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate
1 credit reports, documents containing Plaintiff’s social security number and
2 DOB. Plaintiff has alleged he has suffered harm that could result in
3 production of sensitive medical information, banking records, personal
4 identity information, income tax returns (including attached schedules and
5 forms), W-2 forms and 1099 forms, and personnel or employment records.
6 Accordingly, to expedite the flow of information, to facilitate the prompt
7 resolution of disputes over confidentiality of discovery materials, to
8 adequately protect information the parties are entitled to keep confidential, to
9 ensure that the parties are permitted reasonable necessary uses of such
10 material in preparation for and in the conduct of trial, to address their
11 handling at the end of the litigation, and serve the ends of justice, a protective
12 order for such information is justified in this matter. It is the intent of the
13 parties that information will not be designated as confidential for tactical
14 reasons and that nothing be so designated without a good faith belief that it
15 has been maintained in a confidential, non-public manner, and there is good
16 cause why it should not be part of the public record of this case.
17 1.3 Acknowledgment of Procedure for Filing Under Seal.
18 The parties further acknowledge, as set forth in Section 12.3, below, that this
19 Stipulated Protective Order does not entitle them to file confidential information
20 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed
21 and the standards that will be applied when a party seeks permission from the court
22 to file material under seal.
23 There is a strong presumption that the public has a right of access to
24 judicial proceedings and records in civil cases. In connection with non-
25 dispositive motions, good cause must be shown to support a filing under seal. See
26 Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),
27 Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th
28
1 1999) (even stipulated protective orders require good cause showing), and a
2 specific showing of good cause or compelling reasons with proper evidentiary
3 support and legal justification, must be made with respect to Protected Material
4 that a party seeks to file under seal. The Parties’ mere designation of Disclosure
5 or Discovery Material as CONFIDENTIAL does not—without the submission of
6 competent evidence by declaration, establishing that the material sought to be
7 filed under seal qualifies as confidential, privileged, or otherwise protectable—
8 constitute good cause.
9 Further, if a party requests sealing related to any dispositive motions, briefs,
10 pleadings, deposition transcripts, other papers to be filed with the Court
11 incorporate documents or information subject to this Order, or trial, then the party
12 filing such papers shall designate such materials, or portions thereof, as
13 “Confidential,” and then compelling reasons, not only good cause, for the sealing
14 must be shown, and the relief sought shall be narrowly tailored to serve the
15 specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 605 F.3d
16 665, 677–79 (9th Cir. 2010). For each item or type of information, document, or
17 thing sought to be filed or introduced under seal in connection with a dispositive
18 motion or trial, the party seeking protection must articulate compelling reasons,
19 supported by specific facts and legal justification, for the requested sealing order.
20 Again, competent evidence supporting the application to file documents under
21 seal must be provided by declaration.
22 Any document that is not confidential, privileged, or otherwise protectable
23 in its entirety will not be filed under seal if the confidential portions can be
24 redacted. If documents can be redacted, then a redacted version for public
25 viewing, omitting only the confidential, privileged, or otherwise protectable
26 portions of the document, shall be filed. Any application that seeks to file
27 documents under seal in their entirety should include an explanation of why
28
1 2. DEFINITIONS
2 2.1 Action: Sheree Ali v. I.Q. Data Systems et al. (Case No: 2:24-cv-
3 00391-CBM-KS).
4 2.2 Challenging Party: a Party or Non-Party that challenges the
5 designation of information or items under this Order.
6 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
7 how it is generated, stored or maintained) or tangible things that qualify for
8 protection under Federal Rule of Civil Procedure 26(c), and as specified
9 above in the Good Cause Statement.
10 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
11 their support staff).
12 2.5 Designating Party: a Party or Non-Party that designates information
13 or items that it produces in disclosures or in responses to discovery as
14 “CONFIDENTIAL.”
15 2.6 Disclosure or Discovery Material: all items or information, regardless
16 of the medium or manner in which it is generated, stored, or maintained
17 (including, among other things, testimony, transcripts, and tangible things),
18 that are produced or generated in disclosures or responses to discovery in
19 this matter.
20 2.7 Expert: a person with specialized knowledge or experience in a
21 matter pertinent to the litigation who has been retained by a Party or its
22 counsel to serve as an expert witness or as a consultant in this Action.
23 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses
24 in this Action, with or without prejudice; and (2) final judgment herein after
25 the completion and exhaustion of all appeals, rehearings, remands, trials, or
26 reviews of this Action, including the time limits for filing any motions or
27 applications for extension of time pursuant to applicable law.
28
1 2.9 In-House Counsel: attorneys who are employees of a party to this
2 Action. In-House Counsel does not include Outside Counsel of Record or
3 any other outside counsel.
4 2.10 Non-Party: any natural person, partnership, corporation, association,
5 or other legal entity not named as a Party to this action.
6 2.11 Outside Counsel of Record: attorneys who are not employees of a
7 party to this Action but are retained to represent or advise a party to this
8 Action and have appeared in this Action on behalf of that party or are
9 affiliated with a law firm which has appeared on behalf of that party, and
10 includes support staff.
11 2.12 Party: any party to this Action, including all of its officers, directors,
12 employees, consultants, retained experts, and Outside Counsel of Record
13 (and their support staffs).
14 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
15 Discovery Material in this Action.
16 2.14 Professional Vendors: persons or entities that provide litigation
17 support services (e.g., photocopying, videotaping, translating, preparing
18 exhibits or demonstrations, and organizing, storing, or retrieving data in any
19 form or medium) and their employees and subcontractors.
20 2.15 Protected Material: any Disclosure or Discovery Material and all
21 information derived therefrom (including, but not limited to, all testimony
22 given in a deposition, declaration or otherwise, that refers, reflects or
23 otherwise discusses any information designated “Confidential” that is
24 designated as “CONFIDENTIAL.”
25 2.16 Receiving Party: a Party that receives Disclosure or Discovery
26 Material from a Producing Party.
27
28
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 will be governed by the orders of the
8 trial judge. This Order does not govern the use of Protected Material at trial.
9 4. TRIAL AND DURATION
10 Even after final disposition of this litigation, the confidentiality obligations
11 imposed by this Order will remain in effect until a Designating Party agrees
12 otherwise in writing or a court order otherwise directs. Final disposition will be
13 deemed to be the later of (1) dismissal of all claims and defenses in this Action,
14 with or without prejudice; and (2) final judgment herein after the completion and
15 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
16 including the time limits for filing any motions or applications for extension of
17 time 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
21 under this Order must take care to limit any such designation to specific
22 material that qualifies under the appropriate standards. The Designating
23 Party must designate for protection only those parts of material, documents,
24 items, or oral or written communications that qualify so that other portions
25 of the material, documents, items, or communications for which protection is
26 not warranted are not swept unjustifiably within the ambit of this Order.
27 Mass, indiscriminate, or routinized designations are prohibited.
28
1 Designations that are shown to be clearly unjustified or that have been made
2 for an improper purpose (e.g., to unnecessarily encumber the case development
3 process or to impose unnecessary expenses and burdens on other parties) may
4 expose the Designating Party to sanctions.
5 If it comes to a Designating Party’s attention that information or items that it
6 designated for protection do not qualify for protection, that Designating Party must
7 promptly notify all other Parties that it is withdrawing the inapplicable designation.
8 5.2 Manner and Timing of Designations. Except as otherwise provided in
9 this Order (see, e.g., second paragraph of section 5.2(a) below), or as
10 otherwise stipulated or ordered, Disclosure or Discovery Material that
11 qualifies for protection under this Order must be clearly so designated before
12 the material is disclosed or produced.
13 Designation in conformity with this Order requires:
14 (a) for information in documentary form (e.g., paper or electronic
15 documents, but excluding transcripts of depositions or other pretrial or trial
16 proceedings), that the Producing Party affix at a minimum, the legend
17 “CONFIDENTIAL” to each page that contains protected material. If only a
18 portion or portions of the material on a page qualifies for protection, the
19 Producing Party also must clearly identify the protected portion(s) (e.g., by
20 making appropriate markings in the margins).
21 A Party or Non-Party that makes original documents available for inspection
22 need not designate them for protection until after the inspecting Party has indicated
23 which documents it would like copied and produced. During the inspection and
24 before the designation, all of the material made available for inspection will be
25 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
26 documents it wants copied and produced, the Producing Party must determine
27 which documents, or portions thereof, qualify for protection under this Order.
28 Then, before producing the specified documents, the Producing Party must affix
1 the “CONFIDENTIAL” legend to each page that contains Protected Material. If
2 only a portion or portions of the material on a page qualifies for protection, the
3 Producing Party also must clearly identify the protected portion(s) (e.g., by making
4 appropriate markings in the margins).
5 (b) for testimony given in depositions that the Designating Party identify the
6 Disclosure or Discovery Material on the record, before the close of the
7 deposition all protected testimony.
8 (c) for information produced in some form other than documentary and for
9 any other tangible items, that the Producing Party affix in a prominent place
10 on the exterior of the container or containers in which the information is
11 stored the legend “CONFIDENTIAL.” If only a portion or portions of the
12 information warrants protection, the Producing Party, to the extent
13 practicable, will identify the protected portion(s).
14 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
15 failure to designate qualified information or items does not, standing alone,
16 waive the Designating Party’s right to secure protection under this Order for
17 such material. Upon timely correction of a designation, the Receiving Party
18 must make reasonable efforts to assure that the material is treated in
19 accordance with the provisions of this Order.
20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
21 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
22 designation of confidentiality at any time that is consistent with the Court’s
23 Scheduling Order.
24 6.2 Meet and Confer. The Challenging Party will initiate the dispute
25 resolution process (and, if necessary, file a discovery motion) under Local
26 Rule 37.1 et seq. and with Judge Stevenson’s Civil Procedures.
27 6.3 The burden of persuasion in any such challenge proceeding will be on
28 the Designating Party. Frivolous challenges, and those made for an
1 improper purpose (e.g., to harass or impose unnecessary expenses and
2 burdens on other parties) may expose the Challenging Party to sanctions.
3 Unless the Designating Party has waived or withdrawn the confidentiality
4 designation, all parties will continue to afford the material in question the
5 level of protection to which it is entitled under the Producing Party’s
6 designation until the Court rules on the challenge.
7 7. ACCESS TO AND USE OF PROTECTED MATERIAL
8 7.1 Basic Principles. A Receiving Party may use Protected Material that is
9 disclosed or produced by another Party or by a Non-Party in connection with
10 this Action only for prosecuting, defending, or attempting to settle this
11 Action. Protected Material shall not be used, directly or indirectly, by any
12 person, for any business, commercial or competitive purposes or for any
13 purpose whatsoever other than solely for the preparation for and trial of this
14 action in accordance with the provisions of this Order. Such Protected
15 Material may be disclosed only to the categories of persons and under the
16 conditions described in this Order. When the Action has been terminated, a
17 Receiving Party must comply with the provisions of section 13 below
18 (FINAL DISPOSITION).
19 Protected Material must be stored and maintained by a Receiving Party at a
20 location and in a secure manner that ensures that access is limited to the
21 persons authorized under this Order.
22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
23 otherwise ordered by the court or permitted in writing by the Designating
24 Party, a Receiving Party may disclose any information or item designated
25 “CONFIDENTIAL” only to:
26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
27 well as employees of said Outside Counsel of Record to whom it is
28 reasonably necessary to disclose the information for this Action;
1 (b) the officers, directors, and employees (including House Counsel) of
2 the Receiving Party to whom disclosure is reasonably necessary for this
3 Action;
4 (c) Experts (as defined in this Order) of the Receiving Party to whom
5 disclosure is reasonably necessary for this Action and who have signed
6 the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
7 (d) the Court and its personnel;
8 (e) court reporters and their staff to whom disclosure is reasonably
9 necessary for this Action and who have signed the “Acknowledgment
10 and Agreement to Be Bound” (Exhibit A);
11 (f) professional jury or trial consultants, mock jurors, and Professional
12 Vendors to whom disclosure is reasonably necessary for this Action and
13 who have signed the “Acknowledgment and Agreement to Be Bound”
14 (Exhibit A);
15 (g) the author or recipient of a document containing the information or a
16 custodian or other person who otherwise possessed or knew the
17 information;
18 (h) during their depositions, witnesses, and attorneys for witnesses, in
19 the Action to whom disclosure is reasonably necessary provided: (1) the
20 deposing party requests that the witness sign the form attached as Exhibit
21 A hereto; and (2) they will not be permitted to keep any confidential
22 information unless they sign the “Acknowledgment and Agreement to Be
23 Bound” (Exhibit A), unless otherwise agreed by the Designating Party or
24 ordered by the court. Pages of transcribed deposition testimony or
25 exhibits to depositions that reveal Protected Material may be separately
26 bound by the court reporter and may not be disclosed to anyone except as
27 permitted under this Stipulated Protective Order; and
28
1 (i) any mediator or settlement officer, and their supporting personnel,
2 mutually agreed upon by any of the parties engaged in settlement
3 discussions.
4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED IN OTHER LITIGATION
5
6 If a Party is served with a subpoena or a court order issued in other litigation
7 that compels disclosure of any information or items designated in this Action as
8 “CONFIDENTIAL,” that Party must:
9 (a) promptly notify in writing the Designating Party. Such notification
10 will include a copy of the subpoena or court order;
11 (b) promptly notify in writing the party who caused the subpoena or
12 order to issue in the other litigation that some or all of the material
13 covered by the subpoena or order is subject to this Protective Order.
14 Such notification will include a copy of this Stipulated Protective Order;
15 and
16 (c) cooperate with respect to all reasonable procedures sought to be
17 pursued by the Designating Party whose Protected Material may be
18 affected.
19 If the Designating Party timely seeks a protective order, the Party served
20 with the subpoena or court order will not produce any information designated in
21 this action as “CONFIDENTIAL” before a determination by the court from which
22 the subpoena or order issued, unless the Party has obtained the Designating Party’s
23 permission. The Designating Party will bear the burden and expense of seeking
24 protection in that court of its confidential material and nothing in these provisions
25 should be construed as authorizing or encouraging a Receiving Party in this Action
26 to disobey a lawful directive from another court.
27
28
1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 9.1 Application. The terms of this Order are applicable to
4 information produced by a Non-Party in this Action and designated as
5 “CONFIDENTIAL.” Such information produced by Non-Parties in
6 connection with this litigation is protected by the remedies and relief
7 provided by this Order. Nothing in these provisions should be construed
8 as prohibiting a Non-Party from seeking additional protections.
9 9.2 Notification. In the event that a Party is required, by a valid
10 discovery request, to produce a Non-Party’s confidential information in
11 its possession, and the Party is subject to an agreement with the Non-
12 Party not to produce the Non-Party’s confidential information, then the
13 Party will:
14 (a) promptly notify in writing the Requesting Party and the Non-Party
15 that some or all of the information requested is subject to a
16 confidentiality agreement with a Non-Party;
17 (b) promptly provide the Non-Party with a copy of the Stipulated
18 Protective Order in this Action, the relevant discovery request(s), and
19 a reasonably specific description of the information requested; and
20 (c) make the information requested available for inspection by the
21 Non-Party, if requested.
22 9.3 Conditions of Production.If the Non-Party fails to seek a
23 protective order from this court within 14 days of receiving the notice
24 and accompanying information, the Receiving Party may produce the
25 Non-Party’s confidential information responsive to the discovery request.
26 If the Non-Party timely seeks a protective order, the Receiving Party will
27 not produce any information in its possession or control that is subject to
28 the confidentiality agreement with the Non-Party before a determination
1 by the court. Absent a court order to the contrary, the Non-Party will
2 bear the burden and expense of seeking protection in this court of its
3 Protected Material.
4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
5 If a Receiving Party learns that, by inadvertence or otherwise, it has
6 disclosed Protected Material to any person or in any circumstance not authorized
7 under this Stipulated Protective Order, the Receiving Party must immediately (a)
8 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
9 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
10 the person or persons to whom unauthorized disclosures were made of all the terms
11 of this Order, and (d) request such person or persons to execute the
12 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
13 A.
14 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
OTHERWISE PROTECTED MATERIAL
15
16 When a Producing Party gives notice to Receiving Parties that certain
17 inadvertently produced material is subject to a claim of privilege or other
18 protection, the obligations of the Receiving Parties are those set forth in Federal
19 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
20 whatever procedure may be established in an e-discovery order that provides for
21 production without prior privilege review. Pursuant to Federal Rule of Evidence
22 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
23 of a communication or information covered by the attorney-client privilege or
24 work product protection, the parties may incorporate their agreement in the
25 stipulated protective order submitted to the court.
26
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27
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28
1 12. MISCELLANEOUS
2 12.1 Right to Further Relief. Nothing in this Order abridges the right of
3 any person to seek its modification by the Court in the future.
4 12.2 Right to Assert Other Objections. By stipulating to the entry of this
5 Protective Order no Party waives any right it otherwise would have to object
6 to disclosing or producing any information or item on any ground not
7 addressed in this Stipulated Protective Order. Similarly, no Party waives any
8 right to object on any ground to use in evidence of any of the material
9 covered by this Protective Order.
10 12.3 Filing Protected Material. A Party that seeks to file under seal any
11 Protected Material must comply with Civil Local Rule 79-5. Protected
12 Material may only be filed under seal pursuant to a court order authorizing
13 the sealing of the specific Protected Material at issue. If a Party's request to
14 file Protected Material under seal is denied by the court, then the Receiving
15 Party may file the information in the public record unless otherwise
16 instructed by the court.
17 12.4 Neither the entry of this Order, nor the designation of any
18 information, document, or the like as “Confidential,” nor the failure to make
19 such designation, shall constitute evidence with respect to any issue in this
20 action.
21 13. FINAL DISPOSITION
22 After the final disposition of this Action, as defined in paragraph 4, within
23 60 days, each Receiving Party must return all Protected Material to the Producing
24 Party. As used in this subdivision, “all Protected Material” includes all copies,
25 abstracts, compilations, summaries, and any other format reproducing or capturing
26 any of the Protected Material. The Receiving Party must submit a written
27 certification to the Producing Party (and, if not the same person or entity, to the
28 Designating Party) by the 60 day deadline that (1) identifies (by category, where
1 || appropriate) all the Protected Material that was returned and (2) affirms that the
2 || Receiving Party has not retained any copies, abstracts, compilations, summaries or
3 ||any other format reproducing or capturing any of the Protected Material.
4 || Notwithstanding this provision, Counsel are entitled to retain an archival copy of
5 |}all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
6 || memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
7 || work product, and consultant and expert work product, even if such materials
8 contain Protected Material. Any such archival copies that contain or constitute
9 || Protected Material remain subject to this Protective Order as set forth in Section 4
10 || (DURATION).
11 1/14. VIOLATION
12 Any willful violation of this Order may be punished by civil or criminal
= = 13 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary
= 14 |{|authorities, or other appropriate action at the discretion of the Court.
= g 15 |} IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
ete
“ 16
17 || DATED: May 24, 2024 /s/ Todd Friedman
Attorneys for Plaintiff
18 Matthew Snyder
Todd Friedman
19
20 |} DATED: May 24, 2024 /s/ Joel D. Brodfuehrer
Attorney, for Defendant
21 Joel D. Brodfuehrer
Attorneys for Defendant
22 IQ DATA INTERNATIONAL, INC.
23
24 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
25
26 || DATED: May 28, 2024 7 yao Posinsrr
HON. KAREN L. STEVENSON
27 United States Magistrate Judge
28