Eric Humprey v. Experian Information Solutions, Inc.

1

2

3

4

5

6

7

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10 ERIC HUMPHREY, Case No. 8:23-cv-02116 HDV (JDEx)

11 Plaintiff, STIPULATED PROTECTIVE

ORDER

12

v.

13

EXPERIAN INFORMATION

SOLUTIONS, INC.,

14

Defendant.

15

16

17 Based on the parties’ Stipulation (Dkt. 23) and for good cause shown, the

18 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 Court

24 to enter the following Stipulated Protective Order. The parties acknowledge that

25 this Order does not confer blanket protections on all disclosures or responses to

26 discovery and that the protection it affords from public disclosure and use

27 extends only to the limited information or items that are entitled to confidential

28 treatment under the applicable legal principles.

11

22 2. GOOD CAUSE STATEMENT

33 This action is likely to involve trade secrets, customer and pricing lists and

44 other valuable research, development, commercial, financial, technical and/or

55 proprietary information for which special protection from public disclosure and

66 from use for any purpose other than prosecution of this action is warranted.

77 Such confidential and proprietary materials and information consist of, among

88 other things, confidential business or financial information, information

99 regarding confidential business practices, or other confidential research,

1100 development, or commercial information (including information implicating

1111 privacy rights of third parties), information otherwise generally unavailable to

1122 the public, or which may be privileged or otherwise protected from disclosure

1133 under state or federal statutes, court rules, case decisions, or common law.

1144 Accordingly, to expedite the flow of information, to facilitate the prompt

1155 resolution of disputes over confidentiality of discovery materials, to adequately

1166 protect information the parties are entitled to keep confidential, to ensure that

1177 the parties are permitted reasonable necessary uses of such material in

1188 preparation for and in the conduct of trial, to address their handling at the end

1199 of the litigation, and serve the ends of justice, a protective order for such

2200 information is justified in this matter. It is the intent of the parties that

2211 information will not be designated as confidential for tactical reasons and that

2222 nothing be so designated without a good faith belief that it has been maintained

2233 in a confidential, non-public manner, and there is good cause why it should not

2244 be part of the public record of this case.

2255 3. ACKNOWLEDGMENT OF UNDER SEAL FILING

2266 PROCEDURE

2277 The parties further acknowledge, as set forth in Section 14.3, below, that

2288 this Stipulated Protective Order does not entitle them to file confidential

11 information under seal; Local Civil Rule 79-5 sets forth the procedures that must

22 be followed and the standards that will be applied when a party seeks

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

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

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

66 must be shown to support a filing under seal. See Kamakana v. City and County

77 of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors

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

99 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

1100 require good cause showing), and a specific showing of good cause or

1111 compelling reasons with proper evidentiary support and legal justification, must

1122 be made with respect to Protected Material that a party seeks to file under seal.

1133 The parties’ mere designation of Disclosure or Discovery Material as

1144 CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS’ EYES ONLY does

1155 not— without the submission of competent evidence by declaration, establishing

1166 that the material sought to be filed under seal qualifies as confidential,

1177 privileged, or otherwise protectable—constitute good cause.

1188 Further, if a party requests sealing related to a dispositive motion or trial,

1199 then compelling reasons, not only good cause, for the sealing must be shown,

2200 and the relief sought shall be narrowly tailored to serve the specific interest to be

2211 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir.

2222 2010). For each item or type of information, document, or thing sought to be

2233 filed or introduced under seal, the party seeking protection must articulate

2244 compelling reasons, supported by specific facts and legal justification, for the

2255 requested sealing order. Again, competent evidence supporting the application

2266 to file documents under seal must be provided by declaration.

2277 Any document that is not confidential, privileged, or otherwise

2288 protectable in its entirety will not be filed under seal if the confidential portions

11 can be redacted. If documents can be redacted, then a redacted version for

22 public viewing, omitting only the confidential, privileged, or otherwise

33 protectable portions of the document, shall be filed. Any application that seeks

44 to file documents under seal in their entirety should include an explanation of

55 why redaction is not feasible.

66 4. DEFINITIONS

77 4.1 Action: Eric Humphrey v. Experian Information Solutions, Inc., United

88 States District Court, Central District of California, Case No. 8:23-cv-02116-

99 CJC-JDE.

1100 4.2 Challenging Party: a Party or Non-Party that challenges the

1111 designation of information or items under this Order.

1122 4.3 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ EYES

1133 ONLY” Information or Items: information (regardless of how it is generated,

1144 stored or maintained) or tangible things that qualify for protection under Federal

1155 Rule of Civil Procedure 26(c), and as specified above in the Good Cause

1166 Statement.

1177 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as

1188 their support staff).

1199 4.5 Designating Party: a Party or Non-Party that designates information

2200 or items that it produces in disclosures or in responses to discovery as

2211 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY.”

2222 4.6 Disclosure or Discovery Material: all items or information,

2233 regardless of the medium or manner in which it is generated, stored, or

2244 maintained (including, among other things, testimony, transcripts, and tangible

2255 things), that are produced or generated in disclosures or responses to discovery.

2266 4.7 Expert: a person with specialized knowledge or experience in a

2277 matter pertinent to the litigation who has been retained by a Party or its counsel

2288 to serve as an expert witness or as a consultant in this Action.

11 4.8 House Counsel: attorneys who are employees of a party to this

22 Action. House Counsel does not include Outside Counsel of Record or any

33 other outside counsel.

44 4.9 Non-Party: any natural person, partnership, corporation,

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

66 4.10 Outside Counsel of Record: attorneys who are not employees of a

77 party to this Action but are retained to represent a party to this Action and have

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

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

1100 4.11 Party: any party to this Action, including all of its officers, directors,

1111 employees, consultants, retained experts, and Outside Counsel of Record (and

1122 their support staffs).

1133 4.12 Producing Party: a Party or Non-Party that produces Disclosure or

1144 Discovery Material in this Action.

1155 4.13 Professional Vendors: persons or entities that provide litigation

1166 support services (e.g., photocopying, videotaping, translating, preparing exhibits

1177 or demonstrations, and organizing, storing, or retrieving data in any form or

1188 medium) and their employees and subcontractors.

1199 4.14 Protected Material: any Disclosure or Discovery Material that is

2200 designated as “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’

2211 EYES ONLY.”

2222 4.15 Receiving Party: a Party that receives Disclosure or Discovery

2233 Material from a Producing Party.

2244 5. SCOPE

2255 The protections conferred by this Stipulation and Order cover not only

2266 Protected Material (as defined above), but also (1) any information copied or

2277 extracted from Protected Material; (2) all copies, excerpts, summaries, or

2288 compilations of Protected Material; and (3) any testimony, conversations, or

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

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

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

44 use of Protected Material at trial.

55 6. DURATION

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

77 CONFIDENTIAL or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” or

88 maintained pursuant to this protective order used or introduced as an exhibit at

99 trial becomes public and will be presumptively available to all members of the

1100 public, including the press, unless compelling reasons supported by specific

1111 factual findings to proceed otherwise are made to the trial judge in advance of

1122 the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”

1133 showing for sealing documents produced in discovery from “compelling

1144 reasons” standard when merits-related documents are part of court record).

1155 Accordingly, the terms of this protective order do not extend beyond the

1166 commencement of the trial.

1177 7. DESIGNATING PROTECTED MATERIAL

1188 7.1 Exercise of Restraint and Care in Designating Material for

1199 Protection. Each Party or Non-Party that designates information or

2200 items for protection under this Order must take care to limit any such

2211 designation to specific material that qualifies under the appropriate standards.

2222 The Designating Party must designate for protection only those parts of

2233 material, documents, items or oral or written communications that qualify so

2244 that other portions of the material, documents, items or communications for

2255 which protection is not warranted are not swept unjustifiably within the ambit

2266 of this Order.

2277 Mass, indiscriminate or routinized designations are prohibited.

2288 Designations that are shown to be clearly unjustified or that have been made for

11 an improper purpose (e.g., to unnecessarily encumber the case development

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

33 expose the Designating Party to sanctions.

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

55 that it designated for protection do not qualify for protection, that Designating

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

77 inapplicable designation.

88 7.2 Manner and Timing of Designations. Except as otherwise provided

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

1100 Material that qualifies for protection under this Order must be clearly so

1111 designated before the material is disclosed or produced.

1122 Designation in conformity with this Order requires:

1133 (a) for information in documentary form (e.g., paper or electronic

1144 documents, but excluding transcripts of depositions or other pretrial or trial

1155 proceedings), that the Producing Party affix at a minimum, the legend

1166 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY”

1177 (hereinafter “CONFIDENTIAL legend”), to each page that contains protected

1188 material. If only a portion of the material on a page qualifies for protection, the

1199 Producing Party also must clearly identify the protected portion(s) (e.g., by

2200 making appropriate markings in the margins).

2211 A Party or Non-Party that makes original documents available for

2222 inspection need not designate them for protection until after the inspecting Party

2233 has indicated which documents it would like copied and produced. During the

2244 inspection and before the designation, all of the material made available for

2255 inspection shall be deemed “CONFIDENTIAL” or “CONFIDENTIAL-

2266 ATTORNEYS’ EYES ONLY.” After the inspecting Party has identified the

2277 documents it wants copied and produced, the Producing Party must determine

2288 which documents, or portions thereof, qualify for protection under this Order.

11 Then, before producing the specified documents, the Producing Party must affix

22 the “CONFIDENTIAL legend” to each page that contains Protected Material.

33 If only a portion of the material on a page qualifies for protection, the Producing

44 Party also must clearly identify the protected portion(s) (e.g., by making

55 appropriate markings in the margins).

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

77 identifies the Disclosure or Discovery Material on the record, before the close of

88 the deposition all protected testimony.

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

1100 and for any other tangible items, that the Producing Party affix in a prominent

1111 place on the exterior of the container or containers in which the information is

1122 stored the legend “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’

1133 EYES ONLY.” If only a portion or portions of the information warrants

1144 protection, the Producing Party, to the extent practicable, shall identify the

1155 protected portion(s).

1166 7.3 Inadvertent Failures to Designate. If timely corrected, an

1177 inadvertent failure to designate qualified information or items does not, standing

1188 alone, waive the Designating Party’s right to secure protection under this Order

1199 for such material. Upon timely correction of a designation, the Receiving Party

2200 must make reasonable efforts to assure that the material is treated in accordance

2211 with the provisions of this Order.

2222 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS

2233 8.1. Timing of Challenges. Any Party or Non-Party may challenge a

2244 designation of confidentiality at any time that is consistent with the Court’s

2255 Scheduling Order.

2266 8.2 Meet and Confer. The Challenging Party shall initiate the dispute

2277 resolution process under Local Rule 37-1 et seq.

2288 / / /

11 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a

22 joint stipulation pursuant to Local Rule 37-2.

33 8.4 The burden of persuasion in any such challenge proceeding shall be on

44 the Designating Party. Frivolous challenges, and those made for an improper

55 purpose (e.g., to harass or impose unnecessary expenses and burdens on other

66 parties) may expose the Challenging Party to sanctions. Unless the Designating

77 Party has waived or withdrawn the confidentiality designation, all parties shall

88 continue to afford the material in question the level of protection to which it is

99 entitled under the Producing Party’s designation until the Court rules on the

1100 challenge.

1111 9. ACCESS TO AND USE OF PROTECTED MATERIAL

1122 9.1 Basic Principles. A Receiving Party may use Protected Material that is

1133 disclosed or produced by another Party or by a Non-Party in connection with

1144 this Action only for prosecuting, defending or attempting to settle this Action.

1155 Protected Material shall not be used, directly or indirectly, by any person, for

1166 any business, commercial or competitive purposes or for any purpose

1177 whatsoever other than solely for the preparation for and trial of this action in

1188 accordance with the provisions of this Order. Such Protected Material may be

1199 disclosed only to the categories of persons and under the conditions described in

2200 this Order. When the Action has been terminated, a Receiving Party must

2211 comply with the provisions of section 15 below (FINAL DISPOSITION).

2222 Protected Material must be stored and maintained by a Receiving Party at

2233 a location and in a secure manner that ensures that access is limited to the

2244 persons authorized under this Order.

2255 9.2 Disclosure of “CONFIDENTIAL” or “CONFIDENTIAL -

2266 ATTORNEYS’ EYES ONLY” Information or Items. Unless

2277 otherwise ordered by the court or permitted in writing by the Designating Party,

2288 a Receiving Party may disclose any information or item designated

11 “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS’ EYES ONLY”

22 only to:

33 (a) the Receiving Party’s Outside Counsel of Record in this Action,

44 as well as employees of said Outside Counsel of Record to whom it is

55 reasonably necessary to disclose the information for this Action;

66 (b) the officers, directors, and employees (including House Counsel)

77 of the Receiving Party to whom disclosure is reasonably necessary for this

88 Action;

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

1100 whom disclosure is reasonably necessary for this Action and who have signed

1111 the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

1122 (d) the court and its personnel;

1133 (e) court reporters and their staff;

1144 (f) professional jury or trial consultants, mock jurors, and

1155 Professional Vendors to whom disclosure is reasonably necessary for this Action

1166 and who have signed the “Acknowledgment and Agreement to Be Bound”

1177 (Exhibit A);

1188 (g) the author or recipient of a document containing the information

1199 or a custodian or other person who otherwise possessed or knew the

2200 information;

2211 (h) during their depositions, witnesses, and attorneys for witnesses,

2222 in the Action to whom disclosure is reasonably necessary provided: (1) the

2233 deposing party requests that the witness sign the form attached as Exhibit A

2244 hereto; and (2) they will not be permitted to keep any confidential information

2255 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit

2266 A), unless otherwise agreed by the Designating Party or ordered by the court.

2277 Pages of transcribed deposition testimony or exhibits to depositions that reveal

2288 Protected Material may be separately bound by the court reporter and may not

11 be disclosed to anyone except as permitted under this Stipulated Protective

22 Order; and

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

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

55 discussions.

66 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED

77 PRODUCED IN OTHER LITIGATION

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

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

1100 Action as “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS’ EYES

1111 ONLY” that Party must:

1122 (a) promptly notify in writing the Designating Party. Such

1133 notification shall include a copy of the subpoena or court order;

1144 (b) promptly notify in writing the party who caused the subpoena or

1155 order to issue in the other litigation that some or all of the material covered by

1166 the subpoena or order is subject to this Protective Order. Such notification shall

1177 include a copy of this Stipulated Protective Order; and

1188 (c) cooperate with respect to all reasonable procedures sought to be

1199 pursued by the Designating Party whose Protected Material may be affected. If

2200 the Designating Party timely seeks a protective order, the Party served with the

2211 subpoena or court order shall not produce any information designated in this

2222 action as “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS’ EYES

2233 ONLY” before a determination by the court from which the subpoena or order

2244 issued, unless the Party has obtained the Designating Party’s permission. The

2255 Designating Party shall bear the burden and expense of seeking protection in

2266 that court of its confidential material and nothing in these provisions should be

2277 construed as authorizing or encouraging a Receiving Party in this Action to

2288 disobey a lawful directive from another court.

11

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

33 BE PRODUCED IN THIS LITIGATION

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

55 by a Non-Party in this Action and designated as “CONFIDENTIAL” or

66 “CONFIDENTIAL - ATTORNEYS’ EYES ONLY.” Such information

77 produced by Non-Parties in connection with this litigation is protected by the

88 remedies and relief provided by this Order. Nothing in these provisions should

99 be construed as prohibiting a Non-Party from seeking additional protections.

1100 (b) In the event that a Party is required, by a valid discovery request,

1111 to produce a Non-Party’s confidential information in its possession, and the

1122 Party is subject to an agreement with the Non-Party not to produce the Non-

1133 Party’s confidential information, then the Party shall:

1144 (1) promptly notify in writing the Requesting Party and the Non-

1155 Party that some or all of the information requested is subject to a confidentiality

1166 agreement with a Non-Party;

1177 (2) promptly provide the Non-Party with a copy of the Stipulated

1188 Protective Order in this Action, the relevant discovery request(s), and a

1199 reasonably specific description of the information requested; and

2200 (3) make the information requested available for inspection by the

2211 Non-Party, if requested.

2222 (c) If the Non-Party fails to seek a protective order from this court

2233 within 14 days of receiving the notice and accompanying information, the

2244 Receiving Party may produce the Non-Party’s confidential information

2255 responsive to the discovery request. If the Non-Party timely seeks a protective

2266 order, the Receiving Party shall not produce any information in its possession or

2277 control that is subject to the confidentiality agreement with the Non-Party

2288 before a determination by the court. Absent a court order to the contrary, the

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

22 of its Protected Material.

33 12. UNAUTHORIZED DISCLOSURE OF PROTECTED

44 MATERIAL

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

66 disclosed Protected Material to any person or in any circumstance not

77 authorized under this Stipulated Protective Order, the Receiving Party must

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

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

1100 Protected Material, (c) inform the person or persons to whom unauthorized

1111 disclosures were made of all the terms of this Order, and (d) request such person

1122 or persons to execute the “Acknowledgment an Agreement to Be Bound”

1133 attached hereto as Exhibit A.

1144 13. INADVERTENT PRODUCTION OF PRIVILEGED OR

1155 OTHERWISE PROTECTED MATERIAL

1166 When a Producing Party gives notice to Receiving Parties that certain

1177 inadvertently produced material is subject to a claim of privilege or other

1188 protection, the obligations of the Receiving Parties are those set forth in Federal

1199 Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended to modify

2200 whatever procedure may be established in an e-discovery order that provides for

2211 production without prior privilege review. Pursuant to Federal Rule of Evidence

2222 502(d) and (e), insofar as the parties reach an agreement on the effect of

2233 disclosure of a communication or information covered by the attorney-client

2244 privilege or work product protection, the parties may incorporate their

2255 agreement in the stipulated protective order submitted to the court.

2266 14. MISCELLANEOUS

2277 14.1 Right to Further Relief. Nothing in this Order abridges the right of

2288 any person to seek its modification by the Court in the future.

11 14.2 Right to Assert Other Objections. By stipulating to the entry of this

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

33 disclosing or producing any information or item on any ground not addressed in

44 this Stipulated Protective Order. Similarly, no Party waives any right to object

55 on any ground to use in evidence of any of the material covered by this

66 Protective Order.

77 14.3 Filing Protected Material. A Party that seeks to file under seal any

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

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

1100 the specific Protected Material. If a Party’s request to file Protected Material

1111 under seal is denied by the court, then the Receiving Party may file the

1122 information in the public record unless otherwise instructed by the court.

1133 15. FINAL DISPOSITION

1144 After the final disposition of this Action, as defined in paragraph 6, within

1155 60 days, each Receiving Party must return all Protected Material to the

1166 Producing Party. As used in this subdivision, “all Protected Material” includes

1177 all copies, abstracts, compilations, summaries, and any other format

1188 reproducing or capturing any of the Protected Material. The Receiving Party

1199 must submit a written certification to the Producing Party (and, if not the same

2200 person or entity, to the Designating Party) by the 60-day deadline that (1)

2211 identifies (by category, where appropriate) all the Protected Material that was

2222 returned and (2) affirms that the Receiving Party has not retained any copies,

2233 abstracts, compilations, summaries or any other format reproducing or

2244 capturing any of the Protected Material. Notwithstanding this provision,

2255 Counsel are entitled to retain an archival copy of all pleadings, motion papers,

2266 trial, deposition, and hearing transcripts, legal memoranda, correspondence,

2277 deposition and trial exhibits, expert reports, attorney work product, and

2288 consultant and expert work product, even if such materials contain Protected

1 || Material. Any such archival copies that contain or constitute Protected Material

2 || remain subject to this Protective Order as set forth in Section 6 (DURATION).

3 16. VIOLATION

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

5 || including, without limitation, contempt proceedings and/or monetary

6 || sanctions.

7 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

8

9 || DATED: June 26, 2024

10 gf

11 Lis Ke 8

JO . EARLY

Untted States Magistrate Judge

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

is. __ STIPULATED PROTECTIVE ORDER

11 EXHIBIT A

22 ACKNOWLEDGMENT AN AGREEMENT TO BE BOUND

33

44 I, _____________________________________, declare as follows:

55 1. My address is ________________________________________________.

66 2. My present employer is ________________________________________.

77 3. My present occupation or job description is _________________________.

88 4. I have received a copy of the Stipulated Protective Order entered in this action

99 on _______________, 20___.

1100 5. I have carefully read and understand the provisions of this Stipulated

1111 Protective Order.

1122 6. I will comply with all provisions of this Stipulated Protective Order.

1133 7. I will hold in confidence, and will not disclose to anyone not qualified under

1144 the Stipulated Protective Order, any information, documents or other

1155 materials produced subject to this Stipulated Protective Order.

1166 8. I will use such information, documents or other materials produced subject to

1177 this Stipulated Protective Order only for purposes of this present action.

1188 9. Upon termination of this action, or upon request, I will return and deliver all

1199 information, documents or other materials produced subject to this Stipulated

2200 Protective Order, and all documents or things which I have prepared relating

2211 to the information, documents or other materials that are subject to the

2222 Stipulated Protective Order, to my counsel in this action, or to counsel for the

2233 party by whom I am employed or retained or from whom I received the

2244 documents.

2255 10. I hereby submit to the jurisdiction of this Court for the purposes of enforcing

2266 the Stipulated Protective Order in this action.

2277 ///

2288 ///

11 I declare under penalty of perjury under the laws of the United States that the

22 foregoing is true and correct.

33

44 Executed this ____ day of _____________, 20__, at __________________.

55

66

77

QUALIFIED PERSON

88

99

1100

1111

1122

1133

1144

1155

1166

1177

1188

1199

2200

2211

2222

2233

2244

2255

2266

2277

2288