The opinion
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION
BRADFORD AQUATIC GROUP, LLC Case No. 2:23-cv-09374-MEMF-AJR
and BRADFORD PRODUCTS, LLC,
Plaintiffs, Hon. A. Joel Richlin
v.
[PROPOSED] Stipulated Protective
Order
CONDOR, INC. and DOUGLAS A.
HAVENS,
Defendants.
CONDOR, INC. and DOUGLAS A.
HAVENS
Counter-Plaintiffs
v.
BRADFORD AQUATIC GROUP, LLC,
BRADFORD PRODUCTS, LLC,
SHANE REPOLA, MICHAEL
BRODEUR, DALE BRODEUR, JR,
CINDY BRODEUR, & DOES 1-10,
Inclusive.
Counter-Defendants.
1 1. GENERAL
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 prosecuting
5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and
6 petition the Court to enter the following Stipulated Protective Order. The parties
7 acknowledge that this Order does not confer blanket protections on all disclosures or
8 responses to discovery and that the protection it affords from public disclosure and
9 use extends only to the limited information or items that are entitled to confidential
10 treatment under the applicable legal principles. The parties further acknowledge, as
11 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle
12 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the
13 procedures that must be followed and the standards that will be applied when a party
14 seeks permission from the court to file material under seal.
15 1.2 Good Cause Statement.
16 This action is likely to involve trade secrets, customer and pricing lists and
17 other valuable research, development, commercial, financial, technical and/or
18 proprietary information for which special protection from public disclosure and from
19 use for any purpose other than prosecution of this action is warranted. Such
20 confidential and proprietary materials and information consist of, among other things,
21 confidential business or financial information, information regarding confidential
22 business practices, or other confidential research, development, or commercial
23 information (including information implicating privacy rights of third parties),
24 information otherwise generally unavailable to the public, or which may be privileged
25 or otherwise protected from disclosure under state or federal statutes, court rules, case
26 decisions, or common law. Accordingly, to expedite the flow of information, to
27 facilitate the prompt resolution of disputes over confidentiality of discovery materials,
28 to adequately protect information the parties are entitled to keep confidential, to
1 ensure that the parties are permitted reasonable necessary uses of such material in
2 preparation for and in the conduct of trial, to address their handling at the end of the
3 litigation, and serve the ends of justice, a protective order for such information is
4 justified in this matter. It is the intent of the parties that information will not be
5 designated as confidential for tactical reasons and that nothing be so designated
6 without a good faith belief that it has been maintained in a confidential, non-public
7 manner, and there is good cause why it should not be part of the public record of this
8 case.
9
10 2. DEFINITIONS
11 2.1 Action: this pending federal lawsuit.
12 2.2 Challenging Party: a Party or Non-Party that challenges the designation
13 of information or items under this Order.
14 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
15 how it is generated, stored or maintained) or tangible things that qualify for protection
16 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
17 Cause Statement.
18 2.3.1 “CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Information or
19 Items: Information (regardless of how it is generated, stored, or maintained) or
20 tangible things that qualify for protection under Federal Rule of Civil Procedure 26(c),
21 and, as specified above in the above Good Cause Statement, that is extremely
22 confidential and/or sensitive in nature, the disclosure of which is likely to cause
23 serious economic harm or competitive disadvantage to the Producing Party, or which
24 the Producing Party reasonably believes will seriously compromise or jeopardize its
25 business interests, such that protecting the information cannot be avoided by less
26 restrictive means than designation as “CONFIDENTIAL – ATTORNEYS’ EYES
27 ONLY.” Such information may include, but shall not necessarily be limited to, (i)
28 trade secrets, (ii) confidential research, (iii) development or commercial information,
1 including but not limited to sensitive financial data, technical information, proprietary
2 or nonpublic commercial information, or commercially or competitively sensitive
3 information, (iv) compensation information of current or former employees of a
4 Producing Party, (v) confidential information about clients and customers of a
5 Producing Party, or (vi) technical, marketing, financial, sales or other confidential
6 business information; and would not otherwise be adequately protected under the
7 procedures set forth herein for “CONFIDENTIAL” Discovery Material
8 2.4 Counsel: Outside Counsel of Record (as well as their support staff).
9 2.5 Designating Party: a Party or Non-Party that designates information or
10 items that it produces in disclosures or in responses to discovery as
11 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
12 2.6 Disclosure or Discovery Material: all items or information, regardless
13 of the medium or manner in which it is generated, stored, or maintained (including,
14 among other things, testimony, transcripts, and tangible things), that are produced or
15 generated in disclosures or responses to discovery in this matter.
16 2.7 Expert: a person with specialized knowledge or experience in a matter
17 pertinent to the litigation who has been retained by a Party or its counsel to serve as
18 an expert witness or as a consultant in this Action.
19 2.8 House Counsel: attorneys who are employees of a party to this Action.
20 House Counsel does not include Outside Counsel of Record or any other outside
21 counsel.
22 2.9 Non-Party: any natural person, partnership, corporation, association, or
23 other legal entity not named as a Party to this action.
24 2.10 Outside Counsel of Record: attorneys who are not employees of a party
25 to this Action but are retained to represent or advise a party to this Action and have
26 appeared in this Action on behalf of that party or are affiliated with a law firm that
27 has appeared on behalf of that party, including support staff.
28 2.11 Party: any party to this Action, including all of its officers, directors,
1 employees, consultants, retained experts, and Outside Counsel of Record (and their
2 support staffs).
3 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
4 Discovery Material in this Action.
5 2.13 Professional Vendors: persons or entities that provide litigation support
6 services (e.g., photocopying, videotaping, translating, preparing exhibits or
7 demonstrations, and organizing, storing, or retrieving data in any form or medium)
8 and their employees and subcontractors.
9 2.14 Protected Material: any Disclosure or Discovery Material that is
10 designated as “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES
11 ONLY.”
12 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
13 from a Producing Party.
14
15 3. SCOPE
16 The protections conferred by this Stipulation and Order cover not only
17 Protected Material (as defined above), but also (1) any information copied or extracted
18 from Protected Material; (2) all copies, excerpts, summaries, or compilations of
19 Protected Material; and (3) any testimony, conversations, or presentations by Parties
20 or their Counsel that might reveal Protected Material.
21 Any use of Protected Material at trial shall be governed by the orders of the
22 trial judge. This Order does not govern the use of Protected Material at trial.
23
24 4. DURATION
25 Once a case proceeds to trial, all of the court-filed information to be introduced
26 that was previously designated as confidential or maintained pursuant to this
27 protective order becomes public and will be presumptively available to all members
28 of the public, including the press, unless compelling reasons supported by specific
1 factual findings to proceed otherwise are made to the trial judge in advance of the
2 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir.
3 2006) (distinguishing “good cause” showing for sealing documents produced in
4 discovery from “compelling reasons” standard when merits-related documents are
5 part of court record). Accordingly, the terms of this protective order do not extend
6 beyond the commencement of the trial.
7
8 5. DESIGNATING PROTECTED MATERIAL
9 5.1 Exercise of Restraint and Care in Designating Material for Protection.
10 Each Party or Non-Party that designates information or items for protection under this
11 Order must take care to limit any such designation to specific material that qualifies
12 under the appropriate standards. The Designating Party must designate for protection
13 only those parts of material, documents, items, or oral or written communications that
14 qualify so that other portions of the material, documents, items, or communications
15 for which protection is not warranted are not swept unjustifiably within the ambit of
16 this Order.
17 Mass, indiscriminate, or routinized designations are prohibited. Designations
18 that are shown to be clearly unjustified or that have been made for an improper
19 purpose (e.g., to unnecessarily encumber the case development process or to impose
20 unnecessary expenses and burdens on other parties) may expose the Designating Party
21 to sanctions.
22 If it comes to a Designating Party’s attention that information or items that it
23 designated for protection do not qualify for protection, that Designating Party must
24 promptly notify all other Parties that it is withdrawing the inapplicable designation.
25 5.2 Manner and Timing of Designations. Except as otherwise provided in
26 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
27 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
28
1 under this Order must be clearly so designated before the material is disclosed or
2 produced.
3 Designation in conformity with this Order requires:
4 (a) for information in documentary form (e.g., paper or electronic
5 documents, but excluding transcripts of depositions or other pretrial or trial
6 proceedings), that the Producing Party affix, at a minimum, the legend
7 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
8 (hereinafter “CONFIDENTIAL legend”), to each page that contains protected
9 material. If only a portion or portions of the material on a page qualifies for
10 protection, the Producing Party also must clearly identify the protected portion(s)
11 (e.g., by making appropriate markings in the margins).
12 A Party or Non-Party that makes original documents available for inspection
13 need not designate them for protection until after the inspecting Party has indicated
14 which documents it would like copied and produced. During the inspection and
15 before the designation, all of the material made available for inspection shall be
16 deemed “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES
17 ONLY.” After the inspecting Party has identified the documents it wants copied and
18 produced, the Producing Party must determine which documents, or portions thereof,
19 qualify for protection under this Order. Then, before producing the specified
20 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each
21 page that contains Protected Material. If only a portion or portions of the material on
22 a page qualifies for protection, the Producing Party also must clearly identify the
23 protected portion(s) (e.g., by making appropriate markings in the margins).
24 (b) for testimony given in depositions that the Designating Party identify
25 the Disclosure or Discovery Material on the record, before the close of the deposition.
26 (c) for information produced in some form other than documentary and
27 for any other tangible items, that the Producing Party affix in a prominent place on
28 the exterior of the container or containers in which the information is stored the legend
1 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” If only
2 a portion or portions of the information warrants protection, the Producing Party, to
3 the extent practicable, shall identify the protected portion(s).
4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
5 failure to designate qualified information or items does not, standing alone, waive the
6 Designating Party’s right to secure protection under this Order for such material.
7 Upon timely correction of a designation, the Receiving Party must make reasonable
8 efforts to assure that the material is treated in accordance with the provisions of this
9 Order.
10
11 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
12 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
13 designation of confidentiality at any time that is consistent with the Court’s
14 Scheduling Order.
15 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
16 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly
17 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
18 6.3 Burden. The burden of persuasion in any such challenge proceeding
19 shall be on the Designating Party. Frivolous challenges, and those made for an
20 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
21 other parties) may expose the Challenging Party to sanctions. Unless the Designating
22 Party has waived or withdrawn the confidentiality designation, all parties shall
23 continue to afford the material in question the level of protection to which it is entitled
24 under the Producing Party’s designation until the Court rules on the challenge.
25
26 7. ACCESS TO AND USE OF PROTECTED MATERIAL
27 7.1 Basic Principles. A Receiving Party may use Protected Material that is
28 disclosed or produced by another Party or by a Non-Party in connection with this
1 Action only for prosecuting, defending, or attempting to settle this Action. Such
2 Protected Material may be disclosed only to the categories of persons and under the
3 conditions described in this Order. When the Action has been terminated, a Receiving
4 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
5 Protected Material must be stored and maintained by a Receiving Party at a
6 location and in a secure manner that ensures that access is limited to the persons
7 authorized under this Order.
8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
9 otherwise ordered by the Court or permitted in writing by the Designating Party, a
10 Receiving Party may disclose any information or item designated
11 “CONFIDENTIAL” only to:
12 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
13 well as employees of said Outside Counsel of Record to whom it is reasonably
14 necessary to disclose the information for this Action;
15 (b) the officers, directors, and employees (including House Counsel) of
16 the Receiving Party to whom disclosure is reasonably necessary for this Action;
17 (c) Experts (as defined in this Order) of the Receiving Party to whom
18 disclosure is reasonably necessary for this Action and who have signed the
19 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
20 (d) the Court and its personnel;
21 (e) court reporters and their staff;
22 (f) professional jury or trial consultants, mock jurors, and Professional
23 Vendors to whom disclosure is reasonably necessary for this Action and who have
24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (g) the author or recipient of a document containing the information or
26 a custodian or other person who otherwise possessed or knew the information;
27 (h) during their depositions, witnesses, and attorneys for witnesses, in
28 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
1 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they
2 will not be permitted to keep any confidential information unless they sign the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
4 agreed by the Designating Party or ordered by the Court. Pages of transcribed
5 deposition testimony or exhibits to depositions that reveal Protected Material may be
6 separately bound by the court reporter and may not be disclosed to anyone except as
7 permitted under this Stipulated Protective Order; and
8 (i) any mediator or settlement officer, and their supporting personnel,
9 mutually agreed upon by any of the parties engaged in settlement discussions.
10 7.3 Disclosure of “CONFIDENTIAL – OUTSIDE ATTORNEYS’
11 EYES ONLY” Information or Items. Unless otherwise ordered by the Court or
12 permitted in writing by the Designating Party, a Receiving Party may disclose any
13 information or item designated “CONFIDENTIAL – OUTSIDE ATTORNEYS’
14 EYES ONLY” only to:
15 (a) The Receiving Party’s Outside Counsel of Record in this action, as well
16 as employees of said Outside Counsel of Record to whom it is reasonably necessary
17 to disclose the information for this litigation;
18 (b) Experts (as defined in this Order) of the Receiving Party to whom
19 disclosure is reasonably necessary for this Action and who have signed the
20 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
21 (c) The Court and its personnel;
22 (d) Court reporters and their staff and Professional Vendors to whom
23 disclosure is reasonably necessary for this Action and who have signed the
24 “Acknowledgment and Agreement to be Bound” attached as Exhibit A hereto; and
25 (e) The author or recipient of a document containing the information or a
26 custodian or other person who otherwise possessed or knew the information.
27 (f) Other witnesses or persons to whom the Designating Party agrees in
28 advance of disclosure or by court order.
1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
2 PRODUCED IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation
4 that compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY,” that
6 Party must:
7 (a) promptly notify in writing the Designating Party. Such notification shall
8 include a copy of the subpoena or court order;
9 (b) promptly notify in writing the party who caused the subpoena or order to
10 issue in the other litigation that some or all of the material covered by the subpoena
11 or order is subject to this Protective Order. Such notification shall include a copy of
12 this Stipulated Protective Order; and
13 (c) cooperate with respect to all reasonable procedures sought to be pursued
14 by the Designating Party whose Protected Material may be affected.
15 If the Designating Party timely seeks a protective order, the Party served with
16 the subpoena or court order shall not produce any information designated in this action
17 as “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
18 before a determination by the court from which the subpoena or order issued, unless
19 the Party has obtained the Designating Party’s permission. The Designating Party
20 shall bear the burden and expense of seeking protection in that court of its confidential
21 material and nothing in these provisions should be construed as authorizing or
22 encouraging a Receiving Party in this Action to disobey a lawful directive from
23 another court.
24
25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
26 PRODUCED IN THIS LITIGATION
27 (a) The terms of this Order are applicable to information produced by a Non-
28 Party in this Action and designated as “CONFIDENTIAL” or “CONFIDENTIAL –
1 ATTORNEYS’ EYES ONLY.” Such information produced by Non-Parties in
2 connection with this litigation is protected by the remedies and relief provided by this
3 Order. Nothing in these provisions should be construed as prohibiting a Non-Party
4 from seeking additional protections.
5 (b) In the event that a Party is required, by a valid discovery request, to produce
6 a Non-Party’s confidential information in its possession, and the Party is subject to an
7 agreement with the Non-Party not to produce the Non-Party’s confidential
8 information, then the Party shall:
9 (1) promptly notify in writing the Requesting Party and the Non-Party
10 that some or all of the information requested is subject to a confidentiality agreement
11 with a Non-Party;
12 (2) promptly provide the Non-Party with a copy of the Stipulated
13 Protective Order in this Action, the relevant discovery request(s), and a reasonably
14 specific description of the information requested; and
15 (3) make the information requested available for inspection by the Non-
16 Party, if requested.
17 (c) If the Non-Party fails to seek a protective order from this Court within 14
18 days of receiving the notice and accompanying information, the Receiving Party may
19 produce the Non-Party’s confidential information responsive to the discovery request.
20 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
21 any information in its possession or control that is subject to the confidentiality
22 agreement with the Non-Party before a determination by the Court. Absent a court
23 order to the contrary, the Non-Party shall bear the burden and expense of seeking
24 protection in this Court of its Protected Material.
25
26 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
27 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
28 Protected Material to any person or in any circumstance not authorized under this
1 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
2 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
3 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
4 persons to whom unauthorized disclosures were made of all the terms of this Order,
5 and (d) request such person or persons to execute the “Acknowledgment and
6 Agreement to Be Bound” that is attached hereto as Exhibit A.
7
8 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
9 PROTECTED MATERIAL
10 When a Producing Party gives notice to Receiving Parties that certain
11 inadvertently produced material is subject to a claim of privilege or other protection,
12 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
13 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
14 may be established in an e-discovery order that provides for production without prior
15 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
16 parties reach an agreement on the effect of disclosure of a communication or
17 information covered by the attorney-client privilege or work product protection, the
18 parties may incorporate their agreement in the stipulated protective order submitted
19 to the Court.
20
21 12. MISCELLANEOUS
22 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
23 person to seek its modification by the Court in the future.
24 12.2 Right to Assert Other Objections. By stipulating to the entry of this
25 Protective Order, no Party waives any right it otherwise would have to object to
26 disclosing or producing any information or item on any ground not addressed in this
27 Stipulated Protective Order. Similarly, no Party waives any right to object on any
28 ground to use in evidence of any of the material covered by this Protective Order.
1 12.3 Filing Protected Material. A Party that seeks to file under seal any
2 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
3 only be filed under seal pursuant to a court order authorizing the sealing of the specific
4 Protected Material at issue; good cause must be shown in the request to file under
5 seal. If a Party’s request to file Protected Material under seal is denied by the Court,
6 then the Receiving Party may file the information in the public record unless
7 otherwise instructed by the Court.
8
9 13. FINAL DISPOSITION
10 After the final disposition of this Action, within 60 days of a written request by
11 the Designating Party, each Receiving Party must return all Protected Material to the
12 Producing Party or destroy such material. As used in this subdivision, “all Protected
13 Material” includes all copies, abstracts, compilations, summaries, and any other
14 format reproducing or capturing any of the Protected Material. Whether the Protected
15 Material is returned or destroyed, the Receiving Party must submit a written
16 certification to the Producing Party (and, if not the same person or entity, to the
17 Designating Party) by the 60 day deadline that (1) identifies (by category, where
18 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms
19 that the Receiving Party has not retained any copies, abstracts, compilations,
20 summaries or any other format reproducing or capturing any of the Protected Material.
21 Notwithstanding this provision, counsel are entitled to retain an archival copy of all
22 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
23 correspondence, deposition and trial exhibits, expert reports, attorney work product,
24 and consultant and expert work product, even if such materials contain Protected
25 Material. Any such archival copies that contain or constitute Protected Material
26 remain subject to this Protective Order as set forth in Section 4 (DURATION).
27
28
1 14. VIOLATION OF ORDER
2 Any violation of this Order may be punished by any and all appropriate
3 measures including, without limitation, contempt proceedings and/or monetary
4 sanctions.
5
6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8
DATED: December 12, 2024
9
10 /s/Joseph A. Schouten
Attorneys for Plaintiff(s)
11
12
13
DATED: December 12, 2024
14
15 /s/Gregory K. Clarkson
Attorneys for Defendant(s)
16
17
18 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
19
20 DATED:_1_2_/1_2_/2_0_2_4_______ __________________________________
HON. A. JOEL RICHLIN
21 United States Magistrate Judge
22
23
24
25
26
27
28
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [full name], of _________________
5 [full address], declare under penalty of perjury that I have read in its entirety and
6 understand the Stipulated Protective Order that was issued by the United States
7 District Court for the Central District of California on ____________ [date] in the
8 case of ___________ [insert case name and number]. I agree to comply with and
9 to be bound by all the terms of this Stipulated Protective Order and I understand and
10 acknowledge that failure to so comply could expose me to sanctions and punishment
11 in the nature of contempt. I solemnly promise that I will not disclose in any manner
12 any information or item that is subject to this Stipulated Protective Order to any
13 person or entity except in strict compliance with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court
15 for the Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint __________________________ [full
18 name] of _______________________________________ [full address and
19 telephone number] as my California agent for service of process in connection with
20 this action or any proceedings related to enforcement of this Stipulated Protective
21 Order.
22 Date: ______________________________________
23 City and State where signed: _________________________________
24
25 Printed name: _______________________________
26
27 Signature: __________________________________
28
ATTESTATION PURSUANT TO LOCAL RULE 5-4.3.4
Pursuant to Local Rule 5-4.3.4(a)(2)(i), I attest that all other signatories listed,
and on whose behalf the filing is submitted, concur in the filing’s contents and have
authorized the filing.
/s/Gregory K. Clarkson
Gregory K. Clarkson
CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who are deemed to
have consented to electronic service are being served with this document via the
Court’s CM/ECF system on December 12, 2024.
/s/Gregory K. Clarkson
Gregory K. Clarkson