even stipulated 17 protective orders require good cause showing
How later courts described this case
- even stipulated 17 protective orders require good cause showing
Written by the judges who cited it.
The opinion
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8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 WESTERN DIVISION
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ANNE HEITING, ) Case No. 2:23-cv-08002-SPG-E
12 )
Plaintiff, ) STIPULATED [PROPOSED]
13 ) PROTECTIVE ORDER
v. )
14 )
TARO PHARMACEUTICALS ) Judge: Hon. Honorable Charles F. Eick
15 U.S.A., INC., et al., ) Courtroom: 5C
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16 Defendants. )
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1 1. INTRODUCTION
2 1.1 Purposes and Limitations. Discovery in this action is likely to involve
3 production of confidential, proprietary, or private information for which special
4 protection from public disclosure and from use for any purpose other than
5 prosecuting this litigation may be warranted. Accordingly, the parties hereby
6 stipulate to and petition the court to enter the following Stipulated Protective Order.
7 The parties acknowledge that this Order does not confer blanket protections on all
8 disclosures or responses to discovery and that the protection it affords from public
9 disclosure and use extends only to the limited information or items that are entitled
10 to confidential treatment under the applicable legal principles.
11 1.2 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,
22 court 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
28 information is justified in this matter. It is the intent of the parties that information
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 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties
6 further acknowledge, as set forth in Section 12.3, below, that this Stipulated
7 Protective Order does not entitle them to file confidential information under seal;
8 Local Rule 79-5 sets forth the procedures that must be followed and the standards
9 that will be applied when a party seeks permission from the court to file material
10 under seal.
11 There is a strong presumption that the public has a right of access to judicial
12 proceedings and records in civil cases. In connection with non-dispositive motions,
13 good cause must be shown to support a filing under seal. See Kamakana v. City and
14 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of
15 Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-
16 Welbon v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
17 protective orders require good cause showing), and a specific showing of good
18 cause or compelling reasons with proper evidentiary support and legal justification,
19 must be made with respect to Protected Material that a party seeks to file under seal.
20 The parties’ mere designation of Disclosure or Discovery Material as
21 CONFIDENTIAL does not—without the submission of competent evidence by
22 declaration, establishing that the material sought to be filed under seal qualifies as
23 confidential, privileged, or otherwise protectable—constitute good cause.
24 Further, if a party requests sealing related to a dispositive motion or trial, then
25 compelling reasons, not only good cause, for the sealing must be shown, and the
26 relief sought shall be narrowly tailored to serve the specific interest to be protected.
27 See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each
28 item or type of information, document, or thing sought to be filed or introduced
1 under seal in connection with a dispositive motion or trial, the party seeking
2 protection must articulate compelling reasons, supported by specific facts and legal
3 justification, for the requested sealing order. Again, competent evidence supporting
4 the application to file documents under seal must be provided by declaration.
5 Any document that is not confidential, privileged, or otherwise protectable in
6 its entirety will not be filed under seal if the confidential portions can be redacted.
7 If documents can be redacted, then a redacted version for public viewing, omitting
8 only the confidential, privileged, or otherwise protectable portions of the document,
9 shall be filed. Any application that seeks to file documents under seal in their
10 entirety should include an explanation of why redaction is not feasible.
11
12 2. DEFINITIONS
13 2.1 Action: The above-caption action.
14 2.2 Challenging Party: a Party that challenges the designation of
15 information or items under this Order.
16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
17 how it is generated, stored or maintained) or tangible things that qualify for
18 protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified
19 above in the Good Cause Statement.
20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
21 their support staff).
22 2.5 Designating Party: a Party or Non-Party that designates information or
23 items that it produces in disclosures or in responses to discovery as
24 “CONFIDENTIAL.”
25 2.6 Disclosure or Discovery Material: all items or information, regardless of
26 the medium or manner in which it is generated, stored, or maintained (including,
27 among other things, testimony, transcripts, and tangible things), that are produced or
28 generated in disclosures or responses to discovery in this matter.
1 2.7 Expert: a person with specialized knowledge or experience in a matter
2 pertinent to the litigation who has been retained by a Party or its counsel to serve as
3 an expert witness or as a consultant in this Action.
4 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in
5 this Action, with or without prejudice; and (2) final judgment herein after the
6 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
7 this Action, including the time limits for filing any motions or applications for
8 extension of time pursuant to applicable law.
9 2.9 In-House Counsel: attorneys who are employees of a party to this
10 Action. In-House Counsel does not include Outside Counsel of Record or any other
11 outside counsel.
12 2.10 Non-Party: any natural person, partnership, corporation, association, or
13 other legal entity not named as a Party to this action.
14 2.11 Outside Counsel of Record: attorneys who are not employees of a party
15 to this Action but are retained to represent or advise a party to this Action and have
16 appeared in this Action on behalf of that party or are affiliated with a law firm which
17 has appeared on behalf of that party, and includes support staff.
18 2.12 Party: any party to this Action, including all of its officers, directors,
19 employees, consultants, retained experts, and Outside Counsel of Record (and their
20 support staffs).
21 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
22 Discovery Material in this Action.
23 2.14 Professional Vendors: persons or entities that provide litigation- support
24 services (e.g., photocopying, videotaping, translating, preparing exhibits or
25 demonstrations, and organizing, storing, or retrieving data in any form or medium)
26 and their employees and subcontractors.
27 2.15 Protected Material: any Disclosure or Discovery Material that is
28 designated as “CONFIDENTIAL.”
1 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material
2 from a Producing Party.
3
4 3. SCOPE
5 The protections conferred by this Stipulation and Order cover not only
6 Protected Material (as defined above), but also (1) any information copied or
7 extracted from Protected Material; (2) all copies, excerpts, summaries, or
8 compilations of Protected Material; and (3) any testimony, conversations, or
9 presentations by Parties or their Counsel that might reveal Protected Material.
10 Any use of Protected Material at trial shall be governed by the orders of the
11 trial judge. This Stipulated Protective Order does not govern the use of Protected
12 Material at trial.
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14 4. TRIAL AND DURATION
15 The terms of this Stipulated Protective Order apply through Final Disposition
16 of the Action.
17 Once a case proceeds to trial, information that was designated as
18 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and
19 used or introduced as an exhibit at trial becomes public and will be presumptively
20 available to all members of the public, including the press, unless compelling
21 reasons supported by specific factual findings to proceed otherwise are made to the
22 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81
23 (distinguishing “good cause” showing for sealing documents produced in discovery
24 from “compelling reasons” standard when merits-related documents are part of
25 court record). Accordingly, for such materials, the terms of this Stipulated
26 Protective Order do not extend beyond the commencement of the trial.
27 Even after Final Disposition of this litigation, the confidentiality obligations
28 imposed by this Stipulated Protective Order shall remain in effect until a
1 Designating Party agrees otherwise in writing or a court order otherwise directs.
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3 5. DESIGNATING PROTECTED MATERIAL
4 5.1 Exercise of Restraint and Care in Designating Material for Protection.
5 Each Party or Non-Party that designates information or items for protection under
6 this Order must take care to limit any such designation to specific material that
7 qualifies under the appropriate standards. The Designating Party must designate for
8 protection only those parts of material, documents, items, or oral or written
9 communications that qualify so that other portions of the material, documents, items,
10 or communications for which protection is not warranted are not swept unjustifiably
11 within the ambit of this Order.
12 Mass, indiscriminate, or routinized designations are prohibited. Designations
13 that are shown to be clearly unjustified or that have been made for an improper
14 purpose (e.g., to unnecessarily encumber the case development process or to impose
15 unnecessary expenses and burdens on other parties) may expose the Designating
16 Party to sanctions.
17 If it comes to a Designating Party’s attention that information or items that it
18 designated for protection do not qualify for protection, that Designating Party must
19 promptly notify all other Parties that it is withdrawing the inapplicable designation.
20 5.2 Manner and Timing of Designations. Except as otherwise provided in
21 this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below),
22 or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies
23 for protection under this Stipulated Protective Order must be clearly so designated
24 before the material is disclosed or produced.
25 Designation in conformity with this Stipulated Protective Order requires:
26 (a) for information in documentary form (e.g., paper or electronic
27 documents, but excluding transcripts of depositions or other pretrial or trial
28 proceedings), that the Producing Party affix at a minimum, the legend
1 “CONFIDENTIAL” to each page that contains protected material. If only a portion
2 or portions of the material on a page qualifies for protection, the Producing Party
3 also must clearly identify the protected portion(s) (e.g., by making appropriate
4 markings in the margins).
5 A Party or Non-Party that makes original documents available for inspection
6 need not designate them for protection until after the inspecting Party has indicated
7 which documents it would like copied and produced. During the inspection and
8 before the designation, all of the material made available for inspection shall be
9 deemed CONFIDENTIAL. After the inspecting Party has identified the documents
10 it wants copied and produced, the Producing Party must determine which
11 documents, or portions thereof, qualify for protection under this Stipulated
12 Protective Order. Then, before producing the specified documents, the Producing
13 Party must affix the “CONFIDENTIAL” legend to each page that contains
14 Protected Material. If only a portion or portions of the material on a page qualifies
15 for protection, the Producing Party also must clearly identify the protected
16 portion(s) (e.g., by making appropriate markings in the margins).
17 (b) for testimony given in depositions that the Designating Party identify
18 the Disclosure or Discovery Material on the record, before the close of the
19 deposition all protected testimony.
20 (c) for information produced in some form other than documentary and for
21 any 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
23 “CONFIDENTIAL” legend. If only a portion or portions of the information
24 warrants protection, the Producing Party, to the extent practicable, shall identify the
25 protected 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
28 the Designating Party’s right to secure protection under this Order for such material.
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 Stipulated Protective Order.
4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
5 6.1 Timing of Challenges. Any Party may challenge a designation of
6 confidentiality at any time.
7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
8 resolution process under Local Rule 37.1 et seq.
9 6.3 The burden of persuasion in any such challenge proceeding shall be on
10 the Designating Party. Frivolous challenges, and those made for an improper
11 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
12 parties) may expose the Challenging Party to sanctions. Unless the Designating
13 Party has waived or withdrawn the confidentiality designation, all parties shall
14 continue to afford the material in question the level of protection to which it is
15 entitled under the Producing Party’s designation until the court rules on the
16 challenge.
17
18 7. ACCESS TO AND USE OF PROTECTED MATERIAL
19 7.1 Basic Principles. A Receiving Party may use Protected Material that is
20 disclosed or produced by another Party or by a Non-Party in connection with this
21 Action only for prosecuting, defending, or attempting to settle this Action. Such
22 Protected Material may be disclosed only to the categories of persons and under the
23 conditions described in this Order. When the Action reaches a Final Disposition, a
24 Receiving Party must comply with the provisions of section 13 below.
25 Protected Material must be stored and maintained by a Receiving Party at a
26 location and in a secure manner that ensures that access is limited to the persons
27 authorized under this Stipulated Protective Order.
28 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
1 otherwise ordered by the court or permitted in writing by the Designating Party, a
2 Receiving Party may disclose any information or item designated
3 “CONFIDENTIAL” only:
4 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as
5 well as employees of said Outside Counsel of Record to whom it is reasonably
6 necessary to disclose the information for this Action;
7 (b) to the officers, directors, and employees (including House Counsel) of
8 the Receiving Party to whom disclosure is reasonably necessary for this Action;
9 (c) to Experts (as defined in this Order) of the Receiving Party to whom
10 disclosure is reasonably necessary for this Action and who have signed the
11 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
12 (d) to the court and its personnel;
13 (e) to court reporters and their staff;
14 (f) to professional jury or trial consultants, mock jurors, and Professional
15 Vendors to whom disclosure is reasonably necessary for this Action and who have
16 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17 (g) to the author or recipient of a document containing the information or a
18 custodian or other person who otherwise possessed or knew the information;
19 (h) during their depositions, to witnesses, and attorneys for witnesses, in
20 the Action to whom disclosure is reasonably necessary, provided: (1) the deposing
21 party requests that the witness sign the “Acknowledgment and Agreement to Be
22 Bound” (Exhibit A); and (2) the witness will not be permitted to keep any
23 confidential information unless they sign the “Acknowledgment and Agreement to
24 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or
25 ordered by the court. Pages of transcribed deposition testimony or exhibits to
26 depositions that reveal Protected Material may be separately bound by the court
27 reporter and may not be disclosed to anyone except as permitted under this
28 Stipulated Protective Order; and
1 (i) to any mediator or settlement officer, and their supporting personnel,
2 mutually agreed upon by any of the parties engaged in settlement discussions.
3
4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
5 PRODUCED IN OTHER LITIGATION
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 shall 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 covered by the
13 subpoena or order is subject to this Protective Order. Such notification shall include
14 a copy of this Stipulated Protective Order; and
15 (c) cooperate with respect to all reasonable procedures sought to be
16 pursued by the Designating Party whose Protected Material may be affected.
17 If the Designating Party timely seeks a protective order, the Party served
18 with the subpoena or court order shall not produce any information designated in
19 this action as “CONFIDENTIAL” before a determination by the court from which
20 the subpoena or order issued, unless the Party has obtained the Designating Party’s
21 permission. The Designating Party shall bear the burden and expense of seeking
22 protection in that court of its confidential material and nothing in these provisions
23 should be construed as authorizing or encouraging a Receiving Party in this Action
24 to disobey a lawful directive from another court.
25
26 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
27 PRODUCED IN THIS LITIGATION
28 9.1 Application. The terms of this Stipulated Protective Order are
1 applicable to information produced by a Non-Party in this Action and designated as
2 “CONFIDENTIAL.” Such information produced by Non-Parties in connection
3 with this litigation is protected by the remedies and relief provided by this Order.
4 Nothing in these provisions should be construed as prohibiting a Non-Party from
5 seeking additional protections.
6 9.2 Notification. In the event that a Party is required, by a valid discovery
7 request, to produce a Non-Party’s confidential information in its possession, and the
8 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s
9 confidential information, then the Party shall:
10 (a) promptly notify in writing the Requesting Party and the Non-
11 Party that some or all of the information requested is subject to a confidentiality
12 agreement with a Non-Party;
13 (b) make the information requested available for inspection by the
14 Non-Party, if requested.
15 9.3 Conditions of Production. If the Non-Party fails to seek a protective
16 order from this court within 14 days of receiving the notice and accompanying
17 information, the Receiving Party may produce the Non-Party’s confidential
18 information responsive to the discovery request. If the Non-Party timely seeks a
19 protective order, the Receiving Party shall not produce any information in its
20 possession or control that is subject to the confidentiality agreement with the Non-
21 Party before a determination by the court. Absent a court order to the contrary, the
22 Non-Party shall bear the burden and expense of seeking protection in this court of
23 its Protected Material.
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25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
27 Protected Material to any person or in any circumstance not authorized under this
28 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
1 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
2 to retrieve all unauthorized copies of the Protected Material, (c) inform the person
3 or persons to whom unauthorized disclosures were made of all the terms of this
4 Order, and (d) request such person or persons to execute the “Acknowledgment and
5 Agreement to Be Bound” (Exhibit A).
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7 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
8 PROTECTED MATERIAL
9 When a Producing Party gives notice to Receiving Parties that certain
10 inadvertently produced material is subject to a claim of privilege or other
11 protection, the obligations of the Receiving Parties are those set forth in Rule
12 26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended
13 to modify whatever procedure may be established in an e-discovery order that
14 provides for production without prior privilege review.
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16 12. MISCELLANEOUS
17 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order
18 abridges the right of any person to seek its modification by the court in the future.
19 12.2 Right to Assert Other Objections. By stipulating to the entry of this
20 Stipulated Protective Order no Party waives any right it otherwise would have to
21 object to disclosing or producing any information or item on any ground not
22 addressed in this Stipulated Protective Order. Similarly, no Party waives any right
23 to object on any ground to use in evidence of any of the material covered by this
24 Stipulated Protective Order.
25 12.3 Filing Protected Material. A Party that seeks to file under seal any
26 Protected Material must comply with Local Rule 79-5. Protected Material may only
27 be filed under seal pursuant to a court order authorizing the sealing of the specific
28 Protected Material at issue. If a Party's request to file Protected Material under seal
1 is denied by the court, then the Receiving Party may file the information in the
2 public record unless otherwise instructed by the court.
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4 13. FINAL DISPOSITION
5 After the Final Disposition of this Action, as defined in paragraph 4, within
6 60 days of a written request by the Designating Party, each Receiving Party must
7 return all Protected Material to the Producing Party or destroy such material. As
8 used in this subdivision, “all Protected Material” includes all copies, abstracts,
9 compilations, summaries, and any other format reproducing or capturing any of the
10 Protected Material. Whether the Protected Material is returned or destroyed, the
11 Receiving Party must submit a written certification to the Producing Party (and, if
12 not the same person or entity, to the Designating Party) by the 60 day deadline that
13 (1) identifies (by category, where appropriate) all the Protected Material that was
14 returned or destroyed and (2) affirms that the Receiving Party has not retained any
15 copies, abstracts, compilations, summaries or any other format reproducing or
16 capturing any of the Protected Material. Notwithstanding this provision, Counsel is
17 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
18 and hearing transcripts, legal memoranda, correspondence, deposition and trial
19 exhibits, expert reports, attorney work product, and consultant and expert work
20 product, even if such materials contain Protected Material. Any such archival
21 copies that contain or constitute Protected Material remain subject to this Protective
22 Order as set forth in Section 4.
23 [continued on next page]
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1/14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished by any and
3 appropriate measures including, without limitation, contempt proceedings and/or
4|| monetary sanctions.
5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6
7 DATED: September 20, 2024 ROPES & GRAY LLP
8
By:__/s/ Ryan H. Weinstein
9 Ryan H. Weinstein
10 Attorneys for Defendant
11 TARO PHARMACEUTICALS U.S.A., INC.
12
13 DATED: September 20, 2024. TAUER SMITH LLP
14
By: __/s/ Narain Kumar
15 Robert Tauler
Narain Kumar
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7 Attorneys for Plaintiff
ANNE HEITING
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20|| FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
LEELA
DATED: 9/20/24 —
23 HON. CHARLES F. EICK
UNITED STATES MAGISTRATE JUDGE
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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
6 perjury that I have read in its entirety and understand the Stipulated Protective
7 Order that was issued by the United States District Court for the Central District
8 of California on [date] in the case of __________ [insert formal name of the
9 case and the number and initials assigned to it by the court]. I agree to
10 comply with and to be bound by all the terms of this Stipulated Protective Order
11 and I understand and acknowledge that failure to so comply could expose me to
12 sanctions and punishment in the nature of contempt. I solemnly promise that I
13 will not disclose in any manner any information or item that is subject to this
14 Stipulated Protective Order to any person or entity except in strict compliance
15 with the provisions of this Order.
16 I further agree to submit to the jurisdiction of the United States District Court
17 for the Central District of California for the purpose of enforcing the terms of this
18 Stipulated Protective Order, even if such enforcement proceedings occur after
19 termination of this action. I hereby appoint ________________________ [print
20 or type full name] of ________________________ [print or type full address
21 and telephone number] as my California agent for service of process in
22 connection with this action or any proceedings related to enforcement of this
23 Stipulated Protective Order.
24 ///
25 ///
26 ///
27 ///
28 ///
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2 Date: ___________________________
3 City and State where sworn and signed: ___________________________
4 Printed name: ___________________________
5 Signature: ___________________________
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1 FILER’S ATTESTATION
2 Pursuant to L.R. 5-4.3.4(a)(2)(i), all other signatories listed, and on whose
3 behalf this filing is submitted, concur in this filing’s content and have authorized
4 this filing.
/s/ Ryan H. Weinstein
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Ryan H. Weinstein
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